IR 05000155/1988022

Insp Rept 50-155/88-22 on 881024-28.No Violations Noted. Major Areas Inspected:Radiological Protection Program, Including Organizational & Mgt Controls,Training & Qualifications & Internal & External Exposure Controls

ML20206J173
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/23/1988
From:	Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206J162	List: IR 05000155/1988022 ML20206J160
References
50-155-88-22, IEIN-87-032, IEIN-87-32, IEIN-88-022, IEIN-88-034, IEIN-88-22, IEIN-88-34, NUDOCS 8811280088
Download: ML20206J173 (16)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/88022(DRSS)

Docket No. 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 Site, Charlevoix, Michigan Inspection Conducted: October 24-28, 1988 c4). Ra,J Inspector: W. M Slawinski // - 13 -f8 Date Approved By:

WW L. Robert Greger, Chief y y ,y Emergency Preparedness and Date Radiological Protection Branch t Inspection Summary l

Inspection on October 24-28, 1988 (Report No. 50-155/88022(DRSS))

Areas Inspected: Routine, unannounced inspectici of the radiological protection (core) program (IP 83750), including: organization and management controls; training and qualifications; internal and external exposure controls, control of radioactive materials and contamination; facilities and equipment; the ALARA program; transportation and shipping; and audits and appraisal Also reviewed were previous open items (IP 92701) and licensee internal response to selected NRC Information Notices (IP 92700) including the reported loss of a fission chamber containing special nuclear materia Results: The licensee's radiation protection program appears to be generally affective in protecting the health and safety of occupational workers. One weakness was identified concerning the evaluation of radiological conditions prior to allowing work in an area. No problems were identified with the transportation and shipping of radwaste. Improvements in the ALARA and contamination control programs were note G0089 881123 PDR ADOCK 05000155 Q PDC '..

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DETAILS Per1ons Contacted

• R. Alexander, Technical Engineer

+*J. B2er, Chemistry / Health Physics Superintendent R. BJrdette, Senior Health Physicist

• T. Elward, Plant Manager

+ English, Corporate Health Physics

+*R. Garrett, Chemistry / Health Physics Supervisor T. Hancock, Chemistry / Health Physics Engineer

• L. Monshor, Quality Assurance Superintendent J. Werner, Chemistry / Health Physics Supervisor and ALARA Coordinator

• E. Plettner, NRC Senior Resident Inspector N. Williarsen, NRC Resident Inspector The inspector also contacted other licensee personnel in the Engineering, Instrument and Control, Quality Assurance and Chemistry / Health Physics Department * Denotes those present at the exit meeting on October 28, 1988.

+ Denotes those contacted by telephone on November 1 and 2, 198 ' Gene al This inspection was conducted to review the licensee's operational !

(non-outage) radiation protection program, including organization and management controls, training and qualifications, internal and external <

exposure controls, control of radioactive materials and contamination, facilities equfpment, and audits and appraisals. Also reviewed were past open items, licensee internal response to selected NRC Information -

Noticos, and the reported loss of a fission chamber containing special nuclear materia During plant tours, no significant access control, posting, or procedure adherence problems were identified; plant housekeeping was generally good and somewhat improved over that previously noted (Inspection Report No. 155/88014). The inspector conducted independent direct radiation and contamination surveys of selected plant areas and tools; survey results (smear and direct) were in general agreement with posted licensee dat ; Licensee Action on Previous Inspection Findings (IP 92701)

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(Closed) Open Item (155/88004-011: Ruview effects of Chemistry / Health Physics (C/HP) technician staff reductions on the radiation protection ;

progra Recent hirings have expanded the technician st?ff and improved overall technician experience levels (Section 4).

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(0 pen) Open Item (155/88014-01): Identify the source (s) and reduce the number of low-level personnel contamination events. This item remains open pending further review of contamination control practices, personnel contamination events, and continued licensee efforts to improve contamination controls (Section 8).

(Closed) Unresolved Item (155/88014-02): Rev'ew the circumstances and the apparent anomaly associated with a contamination event that occurred during non-destructive testing. This matter was reviewed further and is described in Section (Open) Open Item (155/88014-03):

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Review management oversight and program to improve radiation worker practices. The licensee continues to evaluate this matter and is considering options to improve worker performance (Section 8).

(0 pen) Ope. Item (155/88014-05): Review adequacy and availability of supplies to control the spread of personnel contamination and for collection of used PCs. This item remains open pending implementation of planned improvements (Section 15). Organization and Management Controls (IP 83750. IP 92701)

The inspector reviewed the licensee's organization and management controls for the radiation protection and ALARA programs including changes in the organizational structure and staffing, management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesse No changes to the Chemistry / Health Physics (C/HP) Department organizational structure have occurred since previously reported (Inspection Report No. 155/88004). The station's permanent C/HP technician staff recently lost one senior technician, but gained two experienced technicians and one trainee. The permanent technician staff currently consists of five Senior Technicians, five Te.chnicians IIs, and one Technician Traine The licensee anticipates that two of the Technician IIs will be promoted to senior technicians in the near future. In addition, one senior contract technician vas retained to supplement the permanent staff for fiscal year 1989. The licensee has conducted the routins radiation protection program with 12 permanent technicians for several years and considers this as the full complemen In approximately the last 15 months, the station's permanent C/HP technician staff lost four persons (33% turnover) due to transfers to other program areas and a health related termination. Recent hirings have filled three of the vaceted positions, two with experienced persons. The interim staff reduct'Oni did not appear to have significantly impacted the radiation protection program; however, job coverage was probably strained during peak work periods. Although no significant adverse effects were identified during the period affected by the staff turnover, continued high turnover would undoubtedly be detrimental to the conduct of the radiation protection program. Staffing and stability will continue to be monitored during future inspection .

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The licensee continues to evaluate previously identified (Inspection Report No. 155/88014) weaknesses in the contamination control program and radiation worker practices. Actions to improve these areas have been partially implemented and several others are under consideration. The station's RPM has recently visited other nuclear plants to eva1uate contamination controls and radiation worker practices. Corporate management involvement and dedication to improve radiation worker practices is also evident and has included a statior visit by a non-technical corporate representative to solicit worker input. As a result, two corporate / station management and worker meetings are scheduled to be held at the stacion to further evaluate and propose actions to improve radiation worker practices. These issues are further discussed in Section At plan % management's request, a comprehensive self-assessment of the plant health physics program was recently conducted by the licensee's corporate health physics office. The assessment details and findings are discussed in Section 1 No violations or deviations were identifie . _ Radiation Protection Training and Qualification (IP 83750)

The inspector reviewed selected aspects of the licensee's radiation protection training program, including program changes, provisions for appropriate radiation protection training of station personnel and se?f-identification and correction of program implementation weaknesse:

As previously described (Inspection Report No. 155/88004), a site INPC audit was conducted in late 1987 to review the C/HP technician train program for accreditation. Problems identified during that visit were

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INP0 accredited in 198 ; Advanced radiation worker training is provided in addition to basic radiation worker training for all persons required to perform work, without "dedicated radiation safety technician coverage," on equipment or components containing, or suspected of containing, radioactivi material which can cause radiation levels in excess of 100 mR/hr. According to the licensee, completion of the twc-day advanced training course allows workers to be issued high radiation area keys and to self-monitor external radiation levels during routine rounds and surveillances. Radiological -

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actual job coverage are provided exclusively by the C/HP staff. Advanced rauiation workers are required by the licensee's Corporate Radiation Safety Plan to requalify every two years by successfully completing a

licensee administered training course. Although advanced radiation worker training is not procedurally required for persons other than C/HP technicians, the license typically qualifies all I&C technicians and operations personnel as advanced radiation workers to reduce the necessity for C/HP technician coverage during routine surveillances and i rounds. In July 1988, the licensee discovered that advanced radiation

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worker training for their six I&C technicians had expired in January 198 The training expiration problem was attributed to an I&C i

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Supervisor who failed to adequately track and schedule training for his staff. Review of this matter showed that a formal and reliable system  !

does not exist to assure advanced radiation worker training requirements

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are met including a means to assure training is verified prior to high radiation area key issuance. No radiological safety problems reportedly resulted from this problem since all I&C technicians have several years ,

plant specific experience including the repeated performance of advanced (

radiation work tasks. Such a system appears needed to prevent recurrence [

of similar problems. This matter was discussed at the exit meeting and l will be reviewed during a future inspection (0 pen Item 155/88022-01). I t

No violations or deviations were identifie . External Exposure Control and Personal Dosimetry (IP 83750)

l The insper. tor reviewed the licensee's personal dosimetry program for compliane.e with 10 CFR 20.202 concerning National Voluntary Laboratory Accreditation Program (NVLAP) requirements for dosimetry processor ,

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The licensee's self-administered dosimetry program employs a Teledyne TLD system that is NVLAP accredited for ANSI-NIL 11 Test Categories II, IV, V, VII, and VII The licensee is not nor did they !

seek NVLAP accreditation for categories I, III, mi VI .:orresponding to .

low-energy photons and high/ low energy photon mixture. The low-energy  !

photons are characteristic of x-ray emissions in the 20-70 Key energy  ;

range. Accorc'ing to preliminary results of a study performed at the '

licensee's Palisades Nuclear Station, characteristic x-rays produced from [

system radioactivity (primarily Fe-55 activation product contamination)  !

do not contribute significantly to either deep or skin dose. According i to the licensee, the results of the study are also applicable to the  !

Big Rock Point Plant. Although the licensee is not NVLAP accredited for {

determining exposure from low-energy photons, they believe any such I exposures are conservatevely determined due to the inherent overresponse i of calcium based TL materials to photon energies less than 100 Ke However, due to replacement part availability and other concerns, the  !

licensee is considering discontinuance of their current TLD system and  !

evaluating another vendors equipment. The licensee plans to initiate .

NVLAP accreditation performance .* sting for a self-administered Panasonic  !

system within the next few month l The total station exposure for 1987 was 211 person-rem, slightly exceeding the projected total of 200. About 145 person-rem has been expended for 1988 through September, primarily (69%) attributed to the nearly .

three month refueling / maintenance outage that concludsd in June. As a result of outage dose savings, the station's initial 1988 dose projection  !

(190 rem) was reduced to about 150 person-re The ALARA pragram is discusscd in Section 1 t

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The station continues to revise / improve the dose tracking system '

previously described in Inspection Report No. 355/88004 and plans to  ;

expand computer dose tracking capabilities to include additional RWP and  !

ALARA exposure information, i I

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No violations or deviations were identifie . Internal Exposure Control and Assessment (IP 837501 The inspector reviewed selected aspects of the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessment; determination whether assessment of individual intakes meet regulatory requirements; use of respiratory protection equipment; 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. Relevant aspects of the program are discussed below, Respiratory e Protection Program Selected arpects of the licensee's respiratory protection program were revieved, including respirator selection, use, accountability, cleaning, and maintenance. Also reviewed were qualifications and training af respiratory protection equipment users and provisions for MPC-hr accountabilit Implementation of the licensee's respiratory protection program is governed by 10 CFR 20 requirements, station procedure RP-37, and a written policy statement on respirator usage. Personnel whose duties may require the use of respiratory protection equipment are required to complete initial training in the use of the equipment, a biennial fit test and an annual medical (pulmonary function) test. The inspector reviewed qualification / training records for sevet11 plant and contractor personnel. Pursuant te procedure RP-37, individual's training and qualifications are required tn be recorded on Form RP-37- Although individuals appeared to meet the training / qualification requirements, pulmonary and fit testing data recorded on Form (s) RP-37-5 were not current and incomplete. These forms are the primary source of information used by C/HP technicians to verify respirator qualifications. According to C/HP Supervision, an alternate source (computer tracking system) was recently instituted to track individual pulmonary and fit testing data and technicians were made aware of the new system. Respiratory training documentation remains on the procedure forms and is not reflected on the computer tracking system. The licensee plans to revise procedure RP-37 to reflect the use of the computer tracking system, consolidate information to avoid confusion and is considering expanding the use of the tracking syste To obtain a respirator, workers report to the C/HP technician office where qualifications are verified and verbal approval is grante Workers then retrieve the appropriate respirator from the storage cabinet in the Turbine Building but are not assigned a particular respirato No method is inplace for worker / respirator accountability

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or traceability. According to the licensee, respirators are seldom used en masse at the same time and the lack of an accountability '

program has not posed significant problems. However, it may be desirable to establish accountability methods particularly when several respirators are used in a given day. In addition, the licensee's respirator return practices create a high probability for cross contamination since returned equipment is not normally individually bagged and, unless problems are suspected, used equipment is not surveyed for contamination prior to cleanin l These areas should be examined by the licensee for possible modification to improve the respiratory protection prograrr.. These matters and the desirability to improve qualification / training !

documentation were discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item 155/88022-02).

Used respirators are hand washed and inspected by C/HP technician A check of respirators ready for issuance indicated that adequate attention is given to inspection and maintenance. No unreturned or l

unused respirators were observed in the plan ,

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MPC-hour accountability methods, procedures, and documei.tation were reviewed. Procedure requirements appear appropriate and were niet; no problems were noted with the MPC-hour accountability program.

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b. Air Sampling Program

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The licensee's routine (non-RWP) air sampling program was reviewe !

Daily short duration air activity simples are collected at the l 585-foot level of the sphere adiacent ?o the recirculation pump room

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and control rod drive accumulator area. Weekly short and long term samples are collected at various sphere and turbine building

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locations including iodine and particulate samples collected at the reactor deck. Continuous air monitors (CAMS) are used in the sphere and turbine building. Samples appear to be collected and evaluated in accordance with applicable procedures; no problems were noted.

! c. Internal Exposure Assessment The licensee's whole-body counting program is similar to that of l Palisades Nuclear Plant (Inspection Report No. 255/87030), except that Big Rock Point uses only one whole body counter (WBC). During i i

the inspection, the procedures for operating the WBC were available at the counting facility and the WBC operator interviewed was aware of the procedural requirements for whole body counting and reporting

, criteria. The licensee performs whole-body counts on radiation !

! workers twice annually and whenever an intake is suspected. The

, licensee's methods for evaluating whole body count results and

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determining MPC-hour uptakes remains as previously described (Inspection Report No. 155/87012). Whole body counter calibration, I functional checks, and maintenance are described in Section 1 !

No violations or deviations were identified, j t

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9 Control of Radioactivo Materials and Contamination (IP 83750, IP 92701)

The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: changes in methodology and procedures; effectiveness of methods of control of radioactive and contaminated materials; programs to improve radiation worker practices; management techniques used to implement the prcgram; and experience concerning self-identification and correction of program implementation weaknesses, Area tontamination Controls and Personnel Contamination Events The licensee's eersonnel contamination event (PCE) identification methods and reporting criteria remain as previously described (Inspection Report No. 155/88014). The station continues to experience low-level PCEs which alarm the contamination monitors but cannot be detected using the conventional hand-held frisker However, the relative frequency of the events have reper:edly been reduced in the last few months because of enhanced plant decontamination efforts and an expanded survey program. The recirculation pump room and steam drum area (which represent the greatest potential source (s) for contamination spread) ventilation system was recently evaluated by an engineer from the licensee's corporate office and determined not to be the source of the low-level contamination problem Air flows were deemed to be appropriat Contamination control and radiation worker practices, and to a lesser extent, noble gas daughter products, appear to be the principal contributors to the problem. The licensee cuntinues to focus efforts toward strengthening contamination controls including expansion of the routine survey program and use of large area n'asslin smears; considerations for improving radiation worker practices; and additional resources for general plant decontamination, including an increased permanent and temporary Janitorial staff and plans to train one or two of the temporary Janitors to assist in decontamination activitie The inspector selectively reviewed personnel contamination reports for 1988 to date. There were 93 skin and 178 clothing contamination events reported during this time. Of this total, 60 skin and 90 clothing events occurred during the refueling / maintenance outage (April 9 through June 26). In 1987, a total of 79 skin contamination events were reported including 66 during the 1987 outage. The station reported 78 skin contaminations during the 1985 outage. This data indicates a significant reduction in the outage PCEs considering that the state-of-the-art whole body friskers were not used prior to the 1988 outag Reportedly, C/HP management personally supervised 1988 refueling activities on the reactor deck, the area which accounts for the majority of contamination events. Although improvements are noted, additional efforts to improve general plant contamination controls and reduce the number of low-level contamination events are needed. To aid in further evaluating radiation worker practices and contamination controls, it appears

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desirable to improve (and standardize) PCE root cause analyses and documentation, routinely track / trend general plant contaminated areas / locations, and establish plant and individual working group goals for PCEs. These matters were discussed at the exit meeting and will continue to be reviewed during future inspection The licensee has not experienced significant problems with hot (discrete) particle Six hot particles have been identified in 1988 to date. Of these six, two were located on workers, the others were located during area surveys. A 0.35 microcuries Co-60 particle was discovered on the calf of ore worker; licensee skin dose calculations showed that no regulatory dose limits were approache The licensee's calculational methods and assumptions were reviewed by the iaspector and appeared appropriate. The event was well documented, b. Tool / Equipment Controls The inspector reviewed the licensee's radiological control program for tools and equipment. Currently, no procedures or specific mechanisms exist to ensure positive control over the issuance, distribution, and return of contaminated and clean too's/ equipment used in radiologically controlled areas (RCAs). Clean and contaminated tools / equipment are stored in several locitions throughout the turbine building including personal too! boxes. Tools used for exclus.1ve applications on contaminated syste.ns in the turbine building pipe tunnel cnd sphere recirculatten pump and lover accumulator rooms are stored in these areas and normally not transferred to other area Inspector surveys (direct and smear) of tools located throughout the turbine building and sphere did not reveal any problems. Tools with fixed contamination were found to be appropriately labeled; no removable activity was identified on any tool The licensee indicated that although no specific mechanisms are established to ensure positive control of tools, no significant radiological problems have been identified to date. Occasional tool accountability problems have been encountered. However, without stronger controls for tool accountability, routine (spot check)

surveying and specifically designated (central) facilities for tool / equipment issuance and return, the probability of releasing potentially contaminated material into non-RCAs is increase The li:ensee is considering modifications to the tool control program to include tool color coding, establishment of a central storage / distribution point for fixed contaminated tools and provisions for including tools / equipment as part of the routine area survey program. These matters were partially discussed at the exit meeting and will continue to be reviewed during future inspections (0 pen Item 155/88022-03).

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. Radiation Worker Practices i As discussed in Section 4, the licensee continues to evaluate radiation worker practices which were identified as a weakness during ;

station QA and INP0 audits (Inspection Report No. 155/88014). A station QA radiation worker surveillance was nearing completion during this inspection and two othar are scheduled for the next few i months (3ection 13).

Several means to improve worker practices are under consideration and ,

include additional training and reinforcing radiation worker responsibilities, enhanced management scrutiny, and a disciplinary ,

action program for workers exhibiting repeated poor practices. The '

licensee is in the process of revising the r.sdiological status sheets .

i posted throughout the plant to be more specific and better delineate !

area entry requirements. Development and effectiveness of programs to -

improve radiation worker practices will continue to be reviewe These matters were discussed at the exit meetin !

No violations or deviations were identified, t f

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9. Contamination Event During Non-Destructive Testing (IP 92701)  !

As previously described (Inspection Report No. 155/88014), three workers involved in ultrasoni: testing of the reactor vessel enclosure studs were i j unexpectedly contaminated both externally and internally. Internal (

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surfaces of the respirators worn by the workers showed unexpectedly high ,

smearable contamination inconsistent with the protection factors routinely I observed by the licensee during fit testing. Particulate protective i factors of 1,000-10,000 are typically measured for negative prest.ure I air purifying full face piece respirators rather than the factor (50) used .

by the licensee and dictated by NRC regulations. However, the actual I respirator contamination levels identified by the licensee after this ;

event were in fact consistent with the air cencentrations measured during the job and a 50 protection factor. This apparent anomaly was not j resolved. fhe licensee suspects the respirator internals were  ;

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breathed during the work activity. This presumption, however, is not f supported by WBC results which showed worker internal dispositions !

(presumably resulting from the work activity) representative of airborne i concentrations higher than those measured during the job. Because of !

3 the many unknown variables involved in this event, no definitive conclusion can be reached regarding the anomal "

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A weakness was identified with the licensee's practice of allowing i radiological work and basing protective requirements and engineering }

controls on assumptions that the work conditions were unchanged from that ;

of previous similar job In the above incident, assumptions regarding i smearable contamination and air activity were based upon previous similar f work. Even though the pre-job radiological conditions may not have been i

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the licensee to stre W m protective requirements / engineering control Also, the documenta' d degree of licensee followup for this event was weak. These r' Jre partially discussed with the licensee at the exit meeting a- .ner discussed in a telecon on November 2, 198 No violations or c' . ons were identified; however, one apparent ,

weakr.ess was noted.

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10. Facilities and Equipment (IP 83750)

The inspector reviewed the operation cf the WBC including calibration, functional checks, and maintenance activities. Procedure RIP-20 outlines operation of the counter and functional check requirements. The licensee l performs weekly system efficiency and gain checks using a cobalt-60 check '

source and records the results in a log. Inspector review of the log revealed that functional check problems were encountered throughout most -

of July and August 1980 in that the cobalt-60 gross count was not within

specified tolerances. No actions were apparently taken for several weeks ;

until the vendor was contacted and recommended minor corrective actions, i

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The existing procedure does not address actions to be taken in such '

instances nor did the log or other records document what transpired. It cppears necessary to strengthen the procedural requirements and trend or maintain equivalent records of counter performance history and maintenance activities. This matter was discussed at the exit meeting and will be ,

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reviewed during a future inspection (0 pen Item 155/88002-04). The most

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recently yearly calibration of the whole body count system, performed by a vendor in January 1988 was reviewed by the inspector; no problems were l note '

The inspector reviewed the operation, alarm setpoint methodology, and calibration procedures for the NMC Gamma-10 portal monitor located in the

security gatehouse. Calibrations are performed annually using a nominal i

200 nanocurie cesium-137 source. The detectors are currently set to alarm, with a high degree of confidence, at about 200 nanocuries. The last calibration was performed in June 1988: detector sensitivities were

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noted to correspond to 1982 factory test results when the unit was

purchased. The inspector noted that health physics responsibilities for responding to portal monitor alarms are not specified in existing

procedures. The inspector alerted the licensee to the potential problems

! of permitting persons to leave the site after alarming the portal monitor ;

, if contamination is not detected on a subseque personal frisk. Unless a q whole body count is performed, internal contamiration or hidden hot i particles may not be identifie The licensee agreed to revise existing

, procedures to address this matter and assure consistency in health physics

] response. This matter will be reviewed during a future inspection (0 pen j Item 155/88022-05). l

No violations or deviations were identified, i

! 11. Maintaining Occupational Exposures ALARA (IP 8*750)

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The inspectors reviewed the licensee's program for maintaining l

occupational exposures ALARA, including

changes in ALARA policy and i 1 procedures; ALARA considerations for maintenance and refueling outages; i I  ;

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establishment of goals and objectives, and effectiveness in meeting the Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesse The ALARA Committee formed in early 1988 (Inspection Report No. 155/88014)

acts in an advisory capacity to plant management by recommending action (s)

on ALARA issues / concerns. Monthly committee meeting minutes were reviewed for 1988 to date. No problems were noted; the committee appears to be functioning as intende Total exposure expended during the 1988 refueling / maintenance outage (April 9 through June 26) was down about 35% from that of the previous two refueling outages. About 100 person-rem (TLD) was expended during the 1988 outage. A near 45% (25 rem) dose savings was realized for ISI activities and attributed to better coordination and plant management oversight, use of additional experienced workers, and a reduction in the number of steam drum inspections performed. On the other hand, limitorque valve work produced more than estimated dose because the licensee replaced old and brittle wiring that was discovered in the system. According to the 18:ensee, the reliability of significant amounts of wiring / cabling located in the steam drum and recirculation pump room areas is also questionable and apparently in need of replacement. This rewiring work'is expected to roughly entail about 2500 man-hours working in general radiation fields of about 300 mrem / hour. The licensee is considering spreading the rewiring work over more than one outage and contemplating various dose saving techniques including recirculation system chemical decontamination. The next scheduled refueling outage will begin in the Spring of 1989. The licensee's decision and course of actions fer this major rewiring task will be followed during subsequent inspection Licensee identified weaknesses during the 1988 v .tage included lack of up-to-date plans / schedules, RWP dose tracking dr ficiencies, and the desirability for more extensive AI. ARA reviews and work group involvemen Overall, the ALARA program has shown imp ovement despite apparent staffing deficiencies (Inspection Report No. 155/88004).

No violations or deviations were identifie . Transportation of Radioactive Materials (IP 83750)

The inspector reviewed selected aspects of the licensee's transportation of radioactive materials program, including: determination whether shipments are in compliance with NRC and DOT regulations; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, and shipment documentation; and experience concerning identification and correction of programmatic weaknesse The inspector selectively reviewed radwaste shipment records for 1988 to dat The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements. Five shipments were made to the Barnwell, South Carolina burial site in 1988 consisting of dewatered resins and

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irradiated metal components. A total volume of about 575 subic feet of waste was shipped thus far in 1988. The licensee indicated that no transportation incidents or significant problems occurred in the last yea No violations or deviations were identifie . Audits and Apprat sals (IP 83750)

The inspector reviewed records of audits and appraisals of radiation protection program activities conducted in 1988 to date and discussed the findings and related issues with members of the QA and C/HP Department Extent and scope of audits /surveillances and adequacy and timeliness of corrective actions taken or proposed were reviewe A comprehensive health physics program assessment was recently conducted at the station by corporate health physics representatives. This assessment, conducted between July 18 and August 12, 1988, was performed at the request of plant management to determine the degree of radiation -

safety plan / program development and its overall implementation. The 1 assessment did not identify any significant problems; no examples of radiation protection practices were found in violation of the station's operating license. Several observations and weaknesses were noted, including lack of a formal hot particle program, lack of a formal supervisory work observation trogram and effective system to keep

management abreast of radiological concerns / incidents, lack of a formal

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plant leak identification and control program anu the need for improved

trending / documentation of plant radiological condit. ions and enhanced training and del',neation of worker responsibilities. Overall, the assessment cited budgetary and staffing restrictions a s the primary i hinderance to program development and enhancement. Tle licensee has not

, yet formulated a plan to address the assessment findiigs; various actions 4 are under consideratio A health physics program survtillance was ccnducted in September 1988 by a '

member of the station's QA group and consisted of a general program overview to determine if mechanisms had been properly established to address previously identified problems and prevent recurrence. No i findings or observations were noted; recommendations to improve program performance were mad The first of three scheduled "radiation worker

practice" surveillances was recently completed by a QA staff membe The

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, surveillance report has yet to be istued. The surveillance methods, scope, and preliminary findings were discussed with the licensee. No ,

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significant problems were identified during the surveillance; l recommendations to improve worker practices and personnel cortamination j event analyses were discusse ,

The licensee began using QA/QC "In-Plant Observation" forms (Inspection Report No. 155/88014) as a means to informally record / trend routine observations of radiation worker practices and housekeeping. Typically, 4 at least one observation form is complet:d by each QA/QC auditor per week; observations are summarized and provided to plant managemen No violations or deviations were identifie .

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14. NRC Information Notice Followup (IP 92700)

The inspector reviewed thc licensee's internal actions to selected NRC Information Notices. The licensee's evaluations, conclusions, and actions are presented below: l Notice No. 87-32: Deficiencies in the Testing of Nuclear-Grade Activated ,

Charcoal. This notice alerts licensee to deficiencies found in the testing of nuclear grade activated charcoal used for accident mitigation in nuclear facilities. This notice is not applicable to Big Rock Point; the licensee has no air cleaning system subject to Technical Specification surveillance requirements. A moisture separator and HEPA filter are located in the offg&s line at the base of the vent stack. Although no '

j in place testing is performed for this HEPA filter, a new HEPA filter,

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certified as meeting standard acceptance criteria, is normally installed l each refueling outage. The chemistry laboratory has a separate unmonitored vent with HEPA filtration. An in place leakage test is i performed annually using 00P and an administrative 1y established '

acceptance criterion of 98 percen "

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Notice No. 88-22: Disposal of Sludge from Onsite Sewage Treatment !

Facilities at Nuclear Power Stations. This notice alerts licensee's to ,

the potential for contamination of sewage sludge and the relevant !

, regulatory requirements for its disposal. Processed sewage treatment '

facility wastes are collected in the station's septic and sludge tank The septic tank accumulates typical sewage system wastes which are

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collected and disposed of by a local vendor four to six times par ye6 Sewage removed fro,n the septic tank is sampled for radioactivity prior to

removal. No radioactivity has been identified in the sewage to date. The l sludge tank accumulates suspended solids from a well-water supplied makeup system. Sludge tank wastes are collected and disposed by a local vendor once every five or more years. The last sludge tank disposal, made in

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late 1987, was reportedly not sampled for radioactivity because tne t licensee does not anticipate activity in this waste stream.

A sludga tank sample collected at the inspectors request showed no l

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radioactivity above background. The licensee agreed to appropriately [

t sample future sludge tank disposal l j appropriately sampled prior to disposa I Notice No. 88-34: Nuclear Material Control and Accountability of Non-Fuel !

3pecial Nuclear Material at Power Reactors. This notice alerts licensees :

e to recent problems involving non-fuel special nuclear material (SNM)

accountability and relevant 10 CFR 70 requirements. As a result of the i i subject notice, the licensee inventoried non-fuel SNM and reviewed related l

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receipt / disposal records and discovered that a fission chamber received in ,

1984 from another utility was unaccountable. A physical search of plant

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, facilities was unable to locate the chamber and the licensee speculates '

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that the material was discarded during a general cleanup of the reactor l deck in 1985 and sent to a licensed disposal facility for buria The chamber was not irradiated and contained two grtms of SNM calculated to be ,

4 microcuries U-235 (93% enriched) and 0.05 microcuries U-238. The '

material does not pose a significant radiological hazar ;

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In accordance with 10 CFR 70.52(a), the NRC was verbally notified of the missing chamber upon discovery on July 15, 1988, and the licensee submitted a followup report dated August 11, 1988. The licensee's accountability program was upgraded to more rigorously incorporate non-fuel SNM pursuant to 10 CFR 70.51 requirements including strengthened procedural control

), over material balance / control areas. The corrective actions taken by the

, licensee appear adeouate to prevent recurrenc l l No inspector identified violations or deviations were note i 1 Tours and Observations (IP 83750. IP 92701) 1

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, The inspector observed housekeeping and radiation protection and '

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contamination control practices during tours of the turbine building and spher No significant problems were noted; however, previously identified concerns (Inspection Report No. 155/88014) regarding supplies to control the spread of personnel contamination and collection of used PCs remain. The licensee indicated that about 30 (30 ga11on) plastic ,

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drums were ordered to replace plastic bags used for PC collection and that !

C/HP technicians and/or janitorial staff members would be instructed to I ensure adequate contamination control supplies are maintained at frisking i

stations. This will continue to be reviewe [

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The inspector performed direct radiation and smear surveys of equiptrent,

tools, and selected areas of the turbine building and sphere. No

problems were noted. About 25 randomly selected tools located throughout the RCA were surveyed; no loose contamination er fixed contamination '

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exceeding labeled levels was identified. Although tool accountability i appears to be lax, no radiological problems were identified a,id the licensee plans to improve tool controls (Secticn 8(b)). '

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No violationA or deviations were identified.

J 1 Exit Mceting (Ip 30703)

The inspector met with licensee representatives (denoted in Section 1) at

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! the conclusion of the inspection on October 28, 1988, and summarized the

scope and findings of the inspection. The apparent weakness related to t

the contamination event discussed in Section 9 was further discussed in a

) telecon on November 2, 1988. The inspector also discussed the itkely i informational content of the inspection report with regard to documents or

! processes reviewed by the inspector during the inspection. The licensee

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did not identify any such documents / processes as proprietary. The following matters were discussed specifically by the inspector.

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! Advanced radiation worker training problems (Section 5).

j The desirability to modify the respiratory protection program (Section 7(a)).

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. The need for continued improvement in contamination controls and l personnel contamination event analyses and documentation, means to audit and improve radiation worker practices, and the desirability  !

to strengthen tool and equipment controls (Section 8). j Concerns associated with the contamination event during non-destructive testing (Section 9). The desirability to improve whole body counter functional test i procedures, methods,anddocumentation(Section10). ,

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