IR 05000155/1986009
| ML20211B066 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/09/1986 |
| From: | Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211B048 | List: |
| References | |
| 50-155-86-09, 50-155-86-9, NUDOCS 8610170120 | |
| Download: ML20211B066 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-155/86009(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 Conductedi September 22-26, 1986 h. f hth Inspector:
D. E. Miller
/o/f[r(a Date'
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Approved By:
L. R.
ger, hief
/6-8 -5 Facilities Radiation Protection Date Section Inspection Sumary Inspection on September 22-26, 1986 (Report No. 50-155/86009(DRSS))
Areas Inspected:
Routine, unannounced inspection of the radiation protection and radwaste management programs, including: organization and
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management controls; training and qualifications; external and internal exposure controls and dosimetry; contamination control; ALARA; solid radwaste;
.and transportation. Also reviewed were past open items.
Results: No violations or deviations were identified.
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DETAILS 1.
Persons Contacted
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- R. Alexander, Technical Engineer
- J. Beer, Chemistry / Radiation Protection (C/RP) Superintendent R. Burdette, C/RP Supervisor
- G. Fox, C/RP Supervisor
- R. Garrett, C/RP Supervisor
- W. Hoaglund, Senior C/RP Technician
- D. Hoffman, Plant Superintendent D. Johnson, Dosimetry Technician
- L. Monshor, Quality Assurance Superintendent S. Guthrie, Senior Resident Inspector The inspector also contacted C/RP technicians and members of the engineering staff during this inspection.
- Attended the September 26, 1986, exit meeting.
2.
General This inspection, which began at 12:15 p.m. on September 22, 1986, was conducted to review operational radiation protection, solid radwaste and transportation, past open items, and a past deviation. Tours of radiologically controlled areas were made. Area postings, access controls, and housekeeping were generally good.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (155/84004-02).and Unresolved Item (155/84004-03):
Procedures allow persons with facial-hair, including members of the fire brigade and radiation protection technicians, to wear SCBAs during emergencies. The licensee has included in their Radiation Protection Plan, and in Administrative Procedure 5.10 " Respiratory Protection and Airborne Contamination Guides," a requirement that fire brigade members must remain clean shaven in the area of the facepiece seal (respiratory device) at all times; this includes C/RP technicians on shift duty.
(Closed) Open Item-(155/84008-01): Need to contact NRR concerning
. disposal of onsite contaminated _ soil pursuant to 10 CFR 20.302. By letter to NRR: dated August 16, 1985,. Consumers Power Company requested approval to r_tain the contaminated soil in place. By letter, dated May 8,1986, John A. Zwolinski to Kenneth W. Berry, the. licensee's request to retain the contaminated soil in place was approved.
(Closed) Open Item (155/84012-01):
Plan to replace Bio-Pak 60P respirators with open circuit SCBAs. The Bio-Pak 60P respirators are no
. longer in service; they have been replaced with SCBAs.
(Closed) Open Item (155/85003-01): Minimal QA surveillances in health physics area. The licensee has increased QA surveillances and audits of the. health physics program. Surveillances and audits of the health physics program are discussed in Section 12.
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(Closed) Deviation (155/85003-02): Failure to implement portions of the Nuclear Operations Department Radiation Safety Plan. The portions of the plan not implemented were a program for performance of planned and scheduled periodic surveillances of the plant's radiation safety program
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.by knowledgeable members of the health physics. staff, and development of
techniques for evaluating radiation. safety incidents. Th'e inspector reviewed corrective actions discussed in the licensee's letter.of
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response dated April 1, 1985; the corrective actions have been
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implemented and appear adequate. Periodic surveillances and techniques for evaluating radiation safety incidents are discussed in Section 4.
4.
Organization and Management Controls
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The inspector reviewed the. licensee's organization and management
" controls for the radiation protection and radwaste programs including changes in the organizational structure and staffing, effectiveness of
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procedures and other. management techniques used to implement-these
programs, experience concerning self-identification and correction of
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program implementation weaknesses, and effectiveness of audits of these
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programs.
i The organizational structure, s'taff, and staffing remain essentially as.
described in Inspection Repor.t No. 50-155/85003. There has been minimal
- turnover of personnel since mid-1985.
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In addition to the audits discussed in Section 12, the licensee has developed and implemented Administrative Procedure 5.16, Health Physics Department Functional Surveillance Program. The procedure establishes a standardized method for conducting functional surveillances within'the i
Health Physics Department to assess the effectiveness of the radiation safety program. The program, implemented during 1986, schedules knowledgeable members of the department to review specific programmatic
areas and report their findings. Several progrannatic weaknesses have been identified during these reviews; corrective measures have been completed or are planned for-these weaknesses. The corrective actions appear adequate.
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Since the inspection conducted in May 1985, the licensee has developed
- and implemented a procedure for investigation of radiological incidents.
The procedure specifies responsible individuals, what type incidents should prompt initiation of an investigation report, what the report
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should contain, and required report distribution and documentation.
According to the licensee, the procedure is under review for possible revision to require enhanced documentation of corrective actions.
During selective review of completed radiological incident investigation reports, the inspector also noted that corrective action documentation
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was not always comprehensive. This matter was discussed with licensee
representatives. Actions taken by the licensee as a result of their review of the radiological incident investigation system will be reviewed during future inspections (155/86009-01).
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No violations or deviations were identified.
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5.
Training and Qualifications The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs,.
including:
changes in responsibilities, policies, goals, programs, and-methods; qualifications of newly hired or promoted radiation protection personnel; and provision of appropriate radiation protection, radwaste, and transportation training for station personnel. Also reviewed were management techniques used to implement these programs and experience-concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section 12.
Chemistry and Health Physics (C/HP) technician training remains essentially as discussed in Inspection Report No. 50-155/85003). The licensee is seeking INP0 accreditation for the training program.
In-addition, all C/HP technicians have at least two years of college; seven have four-year college degrees.
The licensee's training program includes a qualifications program for technician advancement upon ccmpletion of specified practical factors for the four defined technician levels:
technician trainee, technician, technician II, and senior technician. Of the twelve technicians currently on. staff, one is a technician trainee, four are technicians,
one is a technician II, and six are senior technicians.
Technical specification 6.2.2.d requires that a person qualified in
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radiation protection procedures be onsite while fuel is in the reactor.
Based on the licensee's training and qualifications program, technicians above the training level meet this requirement. Currently, all chemistry and health physics technicians are on shift rotation except for the trainee and one senior technician.
The inspector informed the licensee that they are among a handfull of nuclear power plants in the country who are not required to have C/HP technicians who work backshift without health physics supervision meet ANSI N18.1-1971 or more recent requirements. This matter was discussed at the exit meeting and will be reviewed further,during a future inspection.
No violations or deviations were identified.
6.
External Exposure Control and Personal Dosimetery The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section 12.
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Exposure records ~ for plant' and contractor personnel for 1985 and 1986,.to-date, were selectively reviewed. A selective review of Forms NRC-4 was made for.those individuals who exceeded 1.25 rem in a calendar quarter.
No exposures in excess of'10 CFR 20.101 limits were noted. Total dose for 1985 was 325 person-rem by pocket dosimeter; 283 person-rem by TLD.'
No-individual received' greater than four rem at the station during 1985.
Total. dose for.1986 through August was 72 person-rem by pocket-
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dosimeter. Total dose for 1986 is expe'cted to be well below average
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because no refueling outage is planned.
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Dosimetry quality assurance was cursorily reviewed. No problems were
noted.
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During this-inspection period, a licensee quality assurance auditor was performing an audit of the Radiation Work Dermit (RWP) program; the audit
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was requested by the Health Physics Department. A licensee representative
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stated that the RWP program needed revision to make the program
compatible with the ALARA program and to correct other known shortcomings.
The audit was requested in an attempt-to find previously unidentified
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i shortcomings so they could be corrected during programmatic revision'.
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Due to time restraints, the inspector only cursorily reviewed the.RWP program. An inspector will review the licensee's audit. report and program changes during a later inspection (155/86009-02).
No violations or deviations were identified.
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Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting-internal exposure control and personal assessment; determination whether engineering controls,. respiratory equipment,'and assessment of individual intakes meet regulatory requirements; planning and preparation for
maintenance and refueling tasks including ALARA considerations; required records, -_ reports, and notifications; ' effectiveness of management techniques used to implement these programs, and experience concerning
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self-identification and correction of program implementation weaknesses.
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Audits were discussed in Section 12.
The licensee performs whole body counts on radiation workers-twice each
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year and whenever an intake is expected. The inspector reviewed the
results of 275 whole body counts conducted on 247 persons during 1986 through August. No result exceeding the 40 MPC-hour control measure was noted. Several follow-up counts were performed on persons who displayed
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initial elevated counts; most unexpected elevated counts were found to be minor external contamination which was readily removed by showering; only minor quantities of activity were detected in these individuals by whole body counting after showering.
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The licensee has constructed a new respiratory protective device cleaning facility near the laundry facility in the turbine building. The new facility consists of an automatic washer, deep sinks, and air drying racks. Used respirator particulate filters are sent to Palisades Station for testing; those that can be reused are returned to Big Rock Point Station.
The inspector reviewed selected relevant procedures concerning whole body counting and results analysis, and respirator fit testing. No problems were noted.
No violations or deviations were identified.
8.
Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures;
' adequacy of review and dissemination of survey data; and effectiveness of
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methods of control of radioactive and contaminated materials.
The contamination control program remains as described in Inspection Report No. 50-155/05008 except that a janitor is now assigned to perform facility decontamination two or three days per week. Also,C/RP technicians decontaminate small areas as time permits. The licensee stated that plans are being made to hire three contract decontamination technicians for the next refueling outage; this has not been done in the past.
According to licensee records, the extent of contaminated areas, concentration of activity in contaminated areas, and numbers of personal contamination events have trended downward since the janitor was assigned to routine decontamination efforts. The licensee believes that a further long-term reduction in personal contamination events will result from planned additional cleanup of the fuel pool (see Section 9) and enhanced decontamination efforts during refueling.
No violations or deviations were identified.
9.
Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's prog' ram for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the-program and experience concerning self-identification and correction of program implementation weaknesses.
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Several ALARA projects were accomplished during 1985, including:
- Modification of radwaste cask transfer liner to preclude reoccurrence of an incident involving inadvertent opening of the drop bottom.
Provision of enhanced training of travelling repair crew involved in 1985 outage.
Construction of a tent and ventilation unit, for use in cleaning reactor head nuts, to aid in preventing contamination spread.
Implementation of an enhanced contamination reduction program and establishment of decontamination goals.
Changeout of cleanup demineralizer resins at lower dose rates to
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reduce radiation fields for work perfomed in the demineralizer pit.
A major source of incidental exposure at the station is the fuel pool cooling system piping and heat enchangers; the cause apparently is an inefficient fuel pool cleanup system.
In addition to the exposure problem, the inefficient fuel pool cleanup system leads to contamination control problems during refueling operations. To help ~ rectify the problem, the licensee plans to install an underwater filtering system in the fuel pool to supplement the inefficient installed system.
The licensee is also seeking a method of decontaminating the fuel pool cooling system.
The licensee is reviewing ALARA program procedures and~ documentation to identify methods of improving implementation and documentation. The review was prompted by an INP0 finding that the ALARA program is not fully implemented. During the inspector's review of the formal ALARA program and discussions with licensee personnel, the inspector found that the licensee's ALARA documentation does not adequately reflect the effort expended in pre-job and post-job reviews and discussions, job specific planning, and problems encountered.
Possible methods of improvement were discussed with licensee representatives during the inspection and at the exit meeting.
The results of the licensee's review and implementation of ALARA program improvements will be reviewed during later inspections (155/86009-03).
No violations or deviations were identified.
10.
Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses. Audits are discussed in Section 12.
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Solid radwaste handling, compaction, and storage facilities are located in the radwaste building,-which is bounded by a chain link fence outside the protected area. Building and fence lock keys are positively controlled by the HP department.
Radwaste packagings are mainly steel boxes, 55-gallon drums, and high integrity containers (HICs). Resins and filters are placed in HICs and dewatered. HICs are stored in three vaults in the radwaste building before shipment. Dry active wastes are either compacted in 55-gallon drums or are placed in steel boxes. Exposure credited to 1985 radwaste activities was about seven person-rem.
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The inspector toured radwaste handling and storage facilities and discussed radwaste handling with a licensee representative. No significant problems were noted.
No violations or deviations were identified.
11. Transportation of Radioactive Materials The inspector reviewed the licensee's transportation of radioactive materials program, including:
determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; detennination whether shipments are'in compliance with NRC and D0T regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses. Audits are discussed in Section 12.
No violations or deviations were identified.
12. Audits The inspector reviewed onsite and offsite audits of the radiation protection and radwaste management programs performed during 1986 to date. Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewed.
An offsite quality assurance audit of health physics, emergency planning, and packaging and shipping of radioactive materials was performed. There was one finding and two observations in the health physics area. The finding was that implementation of administrative procedures for ALARA and associated radiation work packages was deficient in several areas; a deviation report concerning this matter was written and is being followed by the licensee. The two observations concerned implementation of the dose tracking system and ALARA problem reports. There were two observations in the radwaste shipping area; one concerned lack of proceduralized instructions and one concerned stnrage of records.
Corrective actions for the above finding and observations are in progress.
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Two onsite quality assurance audits.concerning radwaste compaction and documentation, and radioactive. materials controls, were conducted.
There was one deviation and four observations. The deviation concerned inadequate documentation of some radwaste drums meeting acceptance
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criteria as required by procedure; a deviation report was written to track corrective actions. Two. observations concerned procedure compliar.ce problems; two observations concerned improper frisker and portal monitor use. These findings are yet to be followed up on by the licensee. Two additional audits concerning ALARA, RWPs, and survey instruments are yet to be performed during 1986.
Functional surveillances conducted by the Health Physics Department are
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discussed in Section 4.
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The extent of au_dits, qualifications of auditors, and acceptability of
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corrective actions appear adequate.
No violations ~ or deviations were identified.
13, Exit Meeting the inspector met with those noted in Section 1 on May 17,1985 to l
dncuss the scope and findings of the inspection.
The inspector also
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t!!rAussed the likely informational content of the inspection report with retpd to documents or processes reviewed by the inspector during the inspEtion. The licensee identified no such documents / processes as propric tary.
In response to the inspector's coments, the licensee:
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Stated that adequate priority will be given to further reviews and development of corrective procedure revisions for the radiological incident investigation, radiation work permit, and ALARA programs (Sections 4, 6, and 9).
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Acknowledged the inspector's coments concerning qualification requirements for shift C/RP technicians, and stated that they would review the matter to see if they should impose stricter requirements.
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