IR 05000155/1989014

Insp Rept 50-155/89-14 on 890710-0801.Violation Noted.Major Areas Inspected:Radiological Protection Program,Including Changes in Radiation Protection Staff,Audits & Appraisals & Training & Qualification of New Personnel

ML20245K095
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/14/1989
From:	Michael Kunowski, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245K062	List: IR 05000155/1989014 ML20245K058 ML20245K085
References
50-155-89-14, NUDOCS 8908180300
Download: ML20245K095 (8)

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U.S. NUCLEAR REGULATORY COMMISSION .1

REGION III

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ReportSNo. . 50'155/89014(DRSS)-

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, : Docket ~No.'50-155: License'No. DPR-6  !

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' Licensee: . Consumers Power Company l 212 West Michigan ~ Avenue l Jackson, MI=.49201 {

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i Facility Name: Big Rock-Point Nuclear Plant l

Inspection At: Charlevoix, Michigan  !

1. Inspection Conducted: July 10 through August 1, 1989 <l

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L Inspector: M ae A. Kunowski Al (M' [tu .

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h ' Radiation-Specialist Dat(

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i Approved By: M..C.~Schuma'cher, Chief . l Radiological Controls and

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Date  :

Chemistry Section i

Inspection Summary i

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Inspection from July 10 through August 1,1989, (Report No. 50-155/89014(DRSS))

-' Areas Inspected: : Routine, unatinounced inspection of the radiological

,  : protection program (Inspection ~ Procedure IP 83750), including changes in the  !

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radiation protection staff; audits and appraisals; training and qualifications

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of. new personnel; external and internal exposure control including ALARA -

D . considerations;.and control ~ of radioactive material and contamination, Jsurveys, and monitoring. .Also reviewed were previous inspection finding ' : (IP. 92701).' .

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-. Results: The licensee's radiation protection program appears to be effective Ein protecting the health land safety of the public and plant workers. The

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'ALARA and contamination control pregrams are notably active; however, one l," violation was identified for failure .to properly. label contaminated

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equipment (Section 9). i r

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DETAILS Persons Contacted

• R. J. Alexander, Technical Engineer

+*J. L. Beer, Chemistry / Health Physics Superintendent

• T. W. Elward, Plant Manager

• R. J. Garrett, Chemistry / Health Physics Supervisor T. A. Hancock, General Engineer / Chemistry and Health Physics

• R. L. Krchmar, Acting QA Superintendent

• T. F. Popa, ALARA Coordinator G. C. Withrow, Engineering Superintendent

• L. Axelson, Chief, NRC Reactor Projects Branch 2

• R. K. Ewing, NRC Intern

• E. A. Plettner, NRC Senior Resident Inspector

• N. R. Williamsen, NRC Resident Inspector The inspector also contacted other licensee personne *Present at onsite exit meeting on July 13, 1989.

+Present at telephone discussions on July 21 and August 1, 198 . General This inspection was conducted to review the radiation protection program during the annual refueling outag . Licensee Action on Previous Inspection Findings (IP 92701)

(Closed) Unresolved Item (155/88004-02): Review corporate evaluation of whole-body dose assignment methodology to determine if the requirements of Form NRC-5, 10 CFR 20, are met. The licensee's corporate review found no'significant difference between the dosimetry systems used at BRP and at the Palisades station, which was previously determined by the NRC to be in compliance with Form NRC-5 requirements (Inspection Report No. 50-255/88021(DRSS)). Because of the similarity between BRP and Palisades regarding beta source term (165 kev vs. 136 kev) and dose assignment methodology, the unresolved item is close (Closed) Open Item (155/88014-01): Review the licensee's progress in identifying the source (s) and reducing the number of low-level personnel contamination events (PCEs). The licensee was not able to identify any specific, chronic sources of contamination, such as a ventilation system; however, the licensee has developed and is implementing a program to reduce the number of PCEs (see Section 9). The effectiveness of this program will be reviewed as a matter of course in subsequent routine inspection t_ __ _

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(Closed) Open Item (155/88014-03): Review licensee's oversight and ,

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L program to improve radiation worker practices regarding personnel contaminations. The licensee has taken several steps to improve worker performanc Supervisor training for observation of radiation worker-practices has been given and QA/QC inplant reviews have been increase i General employee training is updated periodically to give examples of  !

good and poor radiation worker practices. As noted in Sections 5.and 9, radiation worker (radworker) practices have improved and are generally adequate although weaknesses in control of radioactive materials were l-noted on the.593' level of the turbine building.

L (0 pen) Open Item (155/88014-04): Review initial energy efficiency curves and associated records maintained by the licensee for calibration of the liquid radwaste monitor. A preliminary search for a record of the original energy efficiency calibration of the monitor was unsuccessful, but the licensee is continuing to search for the record. This matter will be reviewed.further at an upcoming inspection of radwaste operation (Closed) Open Item (155/88014-05): Review adequacy of housekeeping and of supplies for controlling spread of personnel contamination in the basement of the turbine building. The licensee has placed shoe covers  ;

at main frisking stations to help control the spread of personnel contamination detected (typically on shoes) at these stations. In addition, the licensee has purchased and is using plastic barrels for trash and used protective clothin (Closed) Open Item (155/88022-01): Formal system does not exist to assure advanced radiation worker training requirements are met. Advanced radiation worker training has been incorporated into the master training

. schedul (Closed) Open Item (155/88022-02): Review respiratory protection program alterations made to limit cross contamination of respirators, improve issuance, return, and accountability of respirators, and improve documentation of user qualifications. The program has been changed to allow for additional control of respirator use and documentation of user qualifications (see Section 8).

(Closed) Open Item (155/88022-03): Review modification to tool / equipment radiological controls. The licensee has established a contaminated (" hot")

tool and equipment control program, including the permanent placement of often-used tools in contaminated areas and the predesignation of hot tool and equipment storage areas and a hot machine sho (Closed) Open Item (155/88022-04): Strengthen procedural requirements and performance history records pertaining to operation of the WBC (whole-body counter). The licensee has strengthened procedural requirements and performance history records pertaining to operation of the WBC. The results of weekly performance checks are now plotted on a graph which has the 2-sigma and 3-sigma limits indicated. The WBC

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! 4 operations proce' dure has been revised to inclu'de instructions to the technician performing the check of the appropriate actions if the results!

~o f the check are'outside of those 2-sigma.and 3-sigma limit (Closed)'Open Item (155/88022-05): Review procedure revisions regarding health physics. response to portal monitor alarms. BRP Administrative Procedure 5.9, Contamination Control, has been revised and adequately specifies the' health physics response to alarms of the portal-monitor in

.the Security. Buildin , Changes in Radiation Protection Staff (IP 83750)

The inspector reviewed changes in the radiation protection organization

. and personnel ..that'could affect occupational radiation protectio No. major' changes have occurred in the Chedstry/ Health Physics (C/HP)

. Department since the previous NRC' radiation protection inspection in 0ctober 1988 (Inspection Report No. 50-155/88022(DRSS)), except for the transfer of-the'ALARA Coordinator to'the Institute of Nuclear Power Operations (INPO). The licensee has filled this position with a C/HP

_ . technician who has had approximately seven years'of experience.at BRP as a technician. This change is not expected to reduce the effectiveness of the radiation protection' program (Section 6).

The technician staff consists of 11 individuals with an average of years.' experience. :Previously, the licensee employed 12 technician To offset the reduction from 12 to 11' technicians, greater responsibility for radiation protection activities was given to workers and greater use is being made of computer data bases. The effects of this staff reduction ori the radiation protection. program will be reviewed at future-inspection No'. deviations or violations of NRC requirements were identifie . Audits and Appraisals (IP 83750)

The-inspecter reviewed surveillance of radiation protection practices made' by the onsite QA group in October 1988 and January - March 198 The auditor noted improvement in radworker practices including areas covered by an earlier industry group audit but expressed concern with control of contaminated tools and equipment particularly around the machine shop. . Similar observations were made by the inspector during the current inspectio The inspector concluded that overall, the licensee is being responsive to the auditors and is making serious efforts to improve the progra Station management requested and received a followup visit from the industry group to review progress and the station RPM has recently observed the' radiation protection program at another nuclear power plant. The station has also adopted a hot particle program in response to a previous corporate radiation protection audit

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• , No!d eviations'or-violations of NRC' requirements were identified.

'! ' 6. _ Training and Qualifications of New Personnel (IP 83750).

' 'The inspector's review of-the resumes of several of the nine contracted technicians. indicated that they were well qualified for the contracted duties; many had been~ at BRP for previous outage Inspector observations of several contracted, technicians working in the plant

. identified-no problems with their performance. According to the licensee, cone technician with only limited experience was not allowed to provide ~ job coverage.but was' assigned tasks commensurate.with her qu'lification a The. inspector did note that several of the resumes for

' contracted technicians had not been updated since 1987 or early 198 'The inspector discussed this observation.with a licensee representative who acknowledged the desirability of maintaining current resume '

As noted. in'Section 4, the licensee has recently filled the ALARA Coordinator position with an individual'with approximately seven years'of experience at BRP as a C/HP technician. Discussion's with this individual and other. licensee representatives, and a review of some recent work.in which he.was involved, indicated that he is enthusiastic and qualified

'for.the position. .The licensee has provided additional. training to him, both onsite and'offsite,'to augment his practical experienc No deviations'or violations of NRC requirements were identifie . External Exposure Control (IP 83750)

The inspector reviewed.the licensee's external exposure control and personal dosimetry programs including: majorchangesintheprogram,

, outage planning and preparation, ALARA considerations, and required

.recordt., reports, and notifications. No problems were identifie The station. dose total in 1988 was 156 person-rem compared to an initial projection of 190 person rem. Lower than anticipated doses were incurred during inservice inspection work (Inspection Report No. 155/88022) and repairs in the clean-up demin pi For 1989, the station projected a dose of 380 person-rem. This estimate was made before the scope of rewiring work in the recirculation pump room was revised (Inspection Report No. 155/88022). The inspector noted that

, the station, especially the C/HP group and the engineering group, made a thorough review of ALARA dose-savings methods for the job (including a review of..the benefits of chemical decontamination of the recirculation piping) and established a job scope that'was estimated to entail a dose that.was an order of magnitude less than the original estimate of

'200-300, person-re Dis'cussions with licensee representatives indicated that the ALARA program has improved since previous NRC radiation protection inspections, t

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with.better general worker attitudes and greater management commitmen The licensee purchased and is'using a video camera to' record specific-

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jobs

and plant components for; training; is pursuing the' purchase of an

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automatedavalve packing extracto'r system, ~has' an active ALARA committee,

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^ and has.followed.up on-several substantive ALARA_ suggestions"and concern

Theinsp~ectorspecificallynots5one.instanceinwhichthelicensee initially ^did not adequately < address"a worker's_ALARA concern, but

subsequently; addressed'the concern, and openly and formally reviewed

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0verall efforts by the licensee for external exposure: control-were goo . 'No deviation or violations of NRC requirements were identifie . - Internal ~ Exposure Control and Assessment'(IP 83750).

'The inspector reviewed the licensee's; interna 1' exposure control and-assessment programs,-including major changes to the programs, planning and preparation for the outage, and ALARA considerations. No major problems were identified. For 1988 and 1989, to date, the license stated that'no' individual had been exposed to airborne radioactivity approaching the 40' MPC-hour' regulatory investigation limi As noted'in Section 3,'the licensee altered the respirator program to provide better control of use. Individually numbered brass tags have v been attached to each respirator and the numbers are recorded on the radiation work permit sign-in sheet when the worker reports to the job-site. In addition, plastic bags are provided with the respirators for

'ba'gging the respirators after use. The number system and bagging allows retrieving a respirator for examination if the worker is found with facial contamination. The licensee has also entered respirator user data into a computer data base which includes information such as date of last respirator' fit test, date of last medical certification, and re' spi _rator user work group. The inspector noted, however, that the

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licensee's. procedures on the respiratory protection program have not been revised to describe the data bas The licensee's whole-body counting program remains essentially as

' described in Inspection Report No. 50-155/88022; However, during the current inspection, the whole-body counter (WBC) was out of service for about-three days; it was-also out of service for about five days in April 1989. Discussions with the licensee and a review of procedures indicated that licensee procedures do not address performing a bioassay or an internal dose assessment when the WBC is out of service. Considering the'recent problems with the WBC, this appears to be a weakness. This concern was discussed at the onsite exit meeting (Section 10) and will be

, reviewed further at a future inspectio !

No deviations or violations of NRC requirements were identifie I

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9.' . Control of Radioactive Materials:and' Contamination, Surveys, and-

. Monitoring JIP 83750)-

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(i' J The; inspector: reviewed portions of the~ licensee's program for~ control c

%m 'of' radioactive materials.and contamination,isurveys, and monit6 tin *

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, :This.revie# included record examination, discussions with licensee:

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representaijives,utours' of ' facilities', and independent' radiation

A, ~ surveys., _ ,

FM :Thetsurveys verified that postings accurately reflected measured exposure

@W q- rates.,;The' inspector! identified a need to clarify-postings in two areas.

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c and:to placeia hand-held-frisker near the machine shop PCM-1B to allow.-

0 workerssto friskinotebooks and clipboards'when leaving the RCA via the

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m' -  : machine' shop. 6The licensee promptly addressed.these concern .

During

~7 mthe. surveys:and.other tours of.the plant, the inspector also observed

housekeeping and'radworker practices. These appeared generall . .

4 - .. satisfactory. ;However,' housekeeping on the-593' elevation ofxthe1 turbine X building'(which includes:the trackway and the machine, shop area) was poo Walkways and work:areasLthere were congested with equipment and bags,of trash. .' Equipment,;such as hand tools-and. hoses, were observed. lyin ; (partially _incontaminatedareasandpartiallyLincleanarea ;The: inspector also observed six bags of contaminated equipment. stored e' iniclean areas within the machine shop and trackway. The bags were no x ~ marked with the contaminationElevels, identification of contents, and date.'which'are req'uired byFSection 5.5.2 of BRP. Administrative

, , (Procsdure 5:11,' Radioactive Material Control. Failure to follow this-procedurevis an apparent violation ~of Technical L5 specification 6.11,.

- 1 , ;which requires adherence'to: procedures;for personnel radiation protection

.(Violation 155/89014-01). By the end of the inspection, the licensee s ' stated that the equipment-had been labelled'as; required, and agreed to

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' remind plant' workers ofsthetprocedural requirement '

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1The licenseeLrecorded 81l personnel-contamination. events (PCEs) in 198 '

< fInL19884 the licensee reported 293 PCEs-(104>skiniand 189 clothing);

this. increase in-PCEs!is attributable to the fact that the licensee began using' very lensiti.ve automated whole-body friskers in March 198 ,

DThe licensee has: expended" substantial effort to reduce PCEs,: including more' frequent cleaning of, floor areas,. strengthened ~ general employee training on radiation worker practices, resurfacing of the refueling deck, testing of decontamination coatings, and establishment of i

department and contractor " goals." The efficacy of the effort will

' be reviewed during a future inspectio ,

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. A review of ~ the licensee's survey program indicated that it is zunconve'ntional in that location-specific survey maps are no longer use lto display survey results. In discussions with the inspector, a licensee

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, ; representative stated that such use is not necessary at BRP because.of the'small and stable workforce and the quality of tile briefings given to

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workers by C/HP technicians. Instead of maps, the licensee uses status E

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i sheets which are posted at the entrance to specific area The

- effectiveness of this practice will be reviewed in greater detail.in subsequent inspection's (0 pen Item 155/89014-02).

<- One' violation was identifie = 1 Exit Meeting (IP 30703)

- The inspector met with^ licensee representatives (tenoted in Section 1) at the. conclusion of the onsite inspection on July'13, 1989, and summarized

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the' scope and tentative' findings of the inspection. Specifically, the,

.following items were discussed by the inspector:

'a . The'~ violation involving failure to properly label bags containing contaminated material (Section 9).

b .' Observations that housekeeping _in.the sphere and on the turbine deck

. were good'but that housekeeping on the ground floor of the turbine-building was poor (Section 9). ,

'The need~to revise current procedures for conducting and documenting

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- bicassays or internal dose assessments when the whole-body counter is out of service (Section 8).

, The. desirability.of maintaining current resumes of contracted C/HP technicians (Section 6). LThe promptness of the HP staff to address inspector concerns about postings and placement of a hand-held frisker by the machine-shop PCM-1B (Section 9). Notable efforts of the station in ALARA, especially regarding the ;

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rewire job in the recirculation pump room'and the final disposition d of a worker's.ALARA concern (Section 7).

Additional telephone discussions regarding survey documentation and the identified violation were held on July 21 and August 1,-1989. During the latter discussion,.the inspector was informed that health physics technicians providing job coverage had been indi.vidually instructed regarding labelling requirements but noted that apparent inconsistencies between the administrative procedure and the corporate Radiation .

Protection Plan were still to be resolved. The inspector stated that l resolution of this matter should be addressed in response to the Notice L of Violatio I i

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