IR 05000155/1992026

Insp Rept 50-155/92-26 on Stated Dates.Violations Noted. Major Areas Inspected:Mgt Control & Organization,Internal & External Exposure & ALARA

ML20126F935
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/24/1992
From:	Schumacher M, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20126F921	List: IR 05000155/1992026 ML20126F919 ML20126F932
References
50-155-92-26, NUDOCS 9212310207
Download: ML20126F935 (8)

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l U.S. NUCLEAR REGULATORY COMMISSION

] REGION III

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! Report No. 50-155/92026(DRSS)

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! 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 i i

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Inspection At: Big Rock Point site, Charlevoix, Michigan j inspection Conducted: November 30 to December 4,1992-

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Inspector: . Shah / 2/:u//<12 '

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Approved By: M. C. Schumacher, Chie / A/v/ /7 2

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Radiological Controls Date' ,

Section 1

i Inspection Summary j Insocction on November 30 to December 4.1992 (Report No. 50-155/92026(DRSS))

Areas InsDected

Routine inspection of the radiation protection program  ;

i (inspection procedure IP) 83750), including _ management control and organization, internal (and external exposure and As low As Reasonably P Achievable (ALARA). Implementation of the new 10 CFR part 20, refueling u outage performanc., cnd the replacement of the #1 recirculation pump seal and- '

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1. 2 heat exchanger were also reviewed.-

Results: The licensee appears to have a good radiation protection program.

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ALARA performance was good given a refueling outage and several forced outages. Source term and exposure reduction initiatives improved with.the i cataloging of stellite containing valves and a successfi'l hydrolazing-of radwaste piping; however, additional effort.is warranted. Three violations, .

two non-cited, were identified during this inspection _for deficiencies in

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. radiological assessment and radioactive material contro >

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DETAILS  ;

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" Persons Contacted

! W. L. Beckman, Plant Manager .

J. L Beer, Superintendent Chemistry and Health Physics E. A Bogue, (Acting) Superintendent Chemistry and Health Physics K. E. Pallagi, Supervisor Radiation Protection R. A. English, Corporate (NPAD) Health Physicist B. Alexander. Technical Engineer G. H. R. Petitjean, Nuclear Performanco Specialist D. R. Hughes, Executive Engineer R. Burdette, Senior Health Physicist R. J. Hill, (NPAD) Senior Assessor T. Popa, ALARA Coordinator T. Tt y Project Engineer, NRC The al ve individuals were present at the exit meeting on December 4, 199 The inspector also interviewed other licensee personne . Licensee Action on Pr3vious Inspection Findinas (IPs 83750 and 84750)

(Closed) Violation (50-155/91017-OlfDRP)): Failure to label containers holding radioactive water from control rod drive flushing activities as

" radioactive." All radiation protection technicians (RPTs) were <

instructed on station labeling criteria and the applicable procedure was corrected for clarification. The inspector noted that corrective actions were prompt and designed to prevent recurrence. This item is close (Closed) Part 21 report concer'iina desian deficiency in Eberline model AMS-3A Beta Particle Air Monitor. The licensee does not use this monitor therefore this item is considered close <

(Closed) IFI (50-155/91018-01(DRSS)): Determination of stack flow rat On August 27, 1992, Consumers Power (CPCo) laboratory personnel measured average flow rates of 41,023 and 42,028 cfm for stack fans #1 and #2, respectively. These values are within 6% of the last measurements taken in 1982 (39,561 cfm stack fan #1; 39,630 cfm stack fan #2). This item is considered close . lig!1tggment Control and Oroanization (IP 8,37.fip1 The_ inspector reviewed the licensee's radiation protection (RP)

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Since the previous inspection, two organizational changes have occurre .

First, a new individual assumed the Superintendent of Health Physics and Chemistry position. This individual has a degree in environmental i science and chemistry, was the former ALARA coordinator at Palisades  :

Nuclear Power Plant, and is working towards health physics +

certification. The previous superintendent will transfer to the '

Palisades Nuclear Power Plant on January 1, 1993. Second, the RP supervisor transferred to the licensee's outage planning _section and was ('

replaced by a senior RPT with over 10 years station experience. While both individuals satisfied station and ANSI N18.1_(1971) requirements,  !

the new RP supervisor needs additional training in trans)ortation regulations prior to certifying radwaste shipments. Altiough the licensee is not currently shipping, this training has been scheduled and any interim shipments will be certified by the senior health physicis No violations or deviations were identifie . External Exposure Control (IP 83750) l

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The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including a review of the refueling outag Selected radiation work permits (RWPs) were reviewed for appropriateness-of the radiation protection requirements based on work scope, location, ,

and radiological conditions. Plant workers were observed adhering to >

RWP requirements and demonstrated their under:tanding in interviews with the inspecto The original refueling outage (RFO) scope was 11/91 - 1/92 with a goal of 212 person-rem. Emergent work forced an extension of the outage until 3/92 and.a total accrued dose of 345 person-rem; Expanded inserviceinspection.(ISI)workwasthemajorcontributortooutage ,

dos Because the plant was at the end of its ten-year ISI cycle, ,

previously postponed work had to be performed during.the outage; -

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primarily in the reactor internals and the steam drum.: Also included *

were weld impressions of-steam piping to alleviate intergranular stress corr % ion cracking concerns. Altogether, 120 person-rem resulted from ISI. Another major. rontributor to RF0 dose was recirculation pump-(RCP)

cable work, .which added 56 person-re ,

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l Total 1992 dose to date, is 275 person-rem,-compared to a revised plant goal of 280 person-rem total for the year. Goal-revision was necessary following the RF0 scope expansion and numerous forced outages from equipment failure; most significant being the bolt repair (inspection report No. 50-155/920ll(DRSS)) and replacement of the #1 RCP seal and #2 RCP heat exchanger. Together, these resulted in an additional- 65 person-rem.. Refueling outage work in 1992 accounted _for 195 person-rem.- ;

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Between 1983 and 1991, station dose remained relatively stable and below the boiling water reactor (BWR) median, but the gap has steadily declined owing to improved industry performance together with the absence of significant source term and exposure reduction efforts by the licensee during this period. This has been recognized by the licensee, and recent initiatives (inspection report No. 50-155/920ll(DRSS) and section Sc) have been take Access to locked high radiation areas (LHRAs) is maintained by both RP and plant operations. For those LHRAs that require o)erator accessibility, three sets of keys are maintained by tie shift supervisor. Radiation protection maintains keys for all plant _LHRAs in a locked cabinet. Keys controlled by either group are required to be checked out in a logbook. Additionally, all plant operators have attended high radiation area training (inspection report No. 50-155/92005(DRSS)). The inspector observed workers exercising good control of LHRA key '

The inspector noted that personnel exposures remained below regulatory limits and that workers appeared cognizant of proper dosimetry placemen No violations or deviations were identifie . Maintainina Occupational Exposures ALF _(IP__Q)]iQ1 The inspector reviewed the licensee's program for maintaining occupational exposures As low As Reasonably Achievable (ALARA). ALARA Proaram/0roanization Management's ALARA policy is stated in the licensee's radiation safety plan and implemented through administrative procedure ALARA res)onsibility is held by the radiation protection (RP)

group wit 1 additional sup) ort from the ALARA committee. The committee is chaired by tie Superintendent of Health Physics and Chemistry, and with the plant manager includes the superintendents of operations, maintenance and engineerin ALARA oversight is through the establishment of station and departmental goals followed by periodic review of performance. A formal cost benefit ratio of $9,000 per person-rem has been established to quantify tangible benefits. Daily aspects of the ALARA program are overseen by the ALARA coordinator with assistance from the RP superviso ALARA policies and practices appear to be well understood by plant workers. Monthly exposure reports are generated by the ALARA coordinator and distributed to department heads. Maintenance and operations personnel indicated that this information had been communicated by their supervisors and used in job plannin Although the ALARA committee meeta quarterly and appears to be

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performing its intended function, no administrative control document exists that describes its responsibilities and organization. This was discussed with the licensee who agreed that the document would serve to underscore management support of ALAR ALARA Implementation

i Administrative procedure 5.2, "ALARA/Projob Planning," implements

! t' licenser s ALARA solicy. It describes both job specific and ,

! 9t -al RWPs and esta)11shes ALARA trigger levels to determine !

app.opriate management review. Estimated exposures less than person-rom are approved by the ALARA coordinator or RP supervisor and require no additional formal review; those above 1.5 person-

rem require an ALARA review and ALARA coordinator approva !

Exposure estimates greater than 15 )erson-rem recuire additional l a) proval by the Plant Manager and tie Superintencent of Health P1ysics and Chemistr Planning for both forced and RF0 work a)peared to effectively l address ALARA concerns and used reasonaale exposure estimate l Daily RF0 meetings were attended by the ALARA coordinator to keep abreast of ongoing work. A list of Rf0 RWPs (active and terminated) indexed by plant location was provided to RP technicians to identify jobs that had been reviewed and a) prove A well documented job history file is maintained by the A; ARA coordinator, and the inspector noted its use during planning for the #1 RCP seal and #2 RCP heat exchanger replacements, it was

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also noted that )ost job reviews had been performed and tnt lessons learned 1ad been incorporated into job planning.

ALARA Initiatives Source term reduction efforts continued with the cataloging of all stellite containing plant valves and an ongoing revision of plant procedures and specifications to require replacement with non-stellite components on an as needed basis. Additionally, the licensee is evaluating the future removal of stellite from turbine bl ades .

As noted in ins)ection report No. 50-155/92025(DRSS), a new ion

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exchange resin las been ordered to reduce iron and copper concentrations in feedwater. Further efforts include an ongoing evaluation to reduce CONO filter porosity from 20-40 microns to 5 or les Although the licensee informally trends hotspots identified during routino surveys, an updated list is not maintained. Also. the inspector noted little initiative in hotspot reductio The licensee is aware of these issues and is planning corrective actions including assigning a RPT to maintain the hotspot lis Regarding hotspot reduction, recent hydrolazing of radwaste piping

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was successful with observed reductions in contact (200-600 mR/hr to 18-40 mR/hr) and general area (30-40 mR/hr to 10-20 mR/hr) dose rates. This was the licensee's first experience with hydrolazing and future use is being evaluate Additional efforts include the assignment of a senior RPT to assist in maintenance job planning and reducing operator entries to high dose area Overall, the licensee's ALARA program appears generally effective. Job planning is well conducted, thorough and properly documented. Workers are cognizant of ALARA and are kept informed of their exposur Management support of ALARA is apparent, although the lack of an administrative control document for the ALARA committee somewhat weakens its effectiveness. Source term and exposure reduction efforts are improving, however additional effort is warranted to remain consistent with industry performance (section 4).

No violations or deviations were identified Internal Exposure Control-(IP 837501-The inspector reviewed the licensee's internal exposure program including calibration of continuous air monitors and respirator maintenance and storag Continuous air monitors (CAMS) identified during plant tours appeared to be in good condition and were calibrated. Alarm levels are determined by 31otting CAM detector efficiency against average beta energy for car)on-14, technetium-99, strontium-90, and chlorine-36 sources. The setpoints are then calculated using-the predicted efficiency for cobalt-60 and its respective maximum permissible concentration (HPC).

> spirators and associated equipment were neatly stored and appeared well maintained, following use, respirators are bagged and returned to RP for washing. Any detectable contamination after washing results in a rewash. Prior to washing, filter cartridges are removed and hand frisked for contamination. If no fixed activity is noted, the cartridges are sent offsite for differential pressure (DP) testin Those passing the DP test are returned to the licensee for reuse. The inspector observed good housekeeping and appropriate postings in the cleaning are The inspector reviewed two instances of Itcensee identified deficiencies involving assessment of radiological conditions prior to work. On february 7, 1992, an operator worked in the RCP room without a resairator for about two hours. _The operator had discussed his entry wit 1 a RPT, who apparently did not recognize that an air sample taken in the RCP room 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> earlier had indicated an -airborne concentration icvel of approximately 17 times MPC. This event was identified later that day by another RPT and the operator was immediately whole body counted (WBC) and an air sample taken of the RCP room. No contamination

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was identified by the whole body count and the air sample indicated less than 25% of HPC. Corrective actions consisted of instructing station RPTs on the importance of properly identifying airborne hazard The second event, on february 14, 1992, involved two RPTs and an engineer who entered the reactor sphere for a general survey and walkdown. All of the individuals were wearing full face particulate respirators. Access to the sphere had been prohibited for approximately '

two days prior to this event, because of integrated leak rate testing !

(ILRT). One RPT accompanied the engineer into the control rod drive, RCP, and steam drum rooms while the other RPT surveyed the sphere .

general area. After the job, the two RPTs identified that air samples '

had not been taken prior to ente.*ing the RCP and steam drum rooms. Air samples taken two days earlier indicated less than 25% of MPC in the rooms. A WOC was performed on both individuals who had entered the rooms and air sam)1es were taken. No internal contamination was identified in eitler individual and air sample results indicated less j than 25% of HP Corrective actions were similar to those following the i february 7, 1992 even I Bnth events involved the failure of the licensee to make an adequate l assessment of the radiological conditions attendant to the work '

performed. Station administrative procedure 5.10 " Respiratory Protection and Airborne Contamination Guides," requires an ALARA evaluation prior to any airborne exposures expected to exceed 20 MPC-hours in a 7 day period, it also requires another air sample be taken if more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since the last air sampling. Both events are violations of technical specification requirement 6.11 which requires adherence to radiation control procedures. Although the february 7 event is not being cited because the criteria specified in Section VII.B. of the " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C) were satisfied, the February 14 event did not meet the criteria because of the apparent failure of corrective actions for the February 7 event and is being cited (violation No. 50-155/92026-01(DRSS)).

Although these events suggest weaknesses in the licensee's assessment of airborne hazards, the inspector determined that the events appeared to be isolated and resulted from personal errors on the part of the individuals involved rather than a lack of understanding of licenzee requirement One non-cited and one cited violation were identifie . Control of Radfoactive Materials and Contamination. Surveys and Monitorina (IP 83750)

The inspector reviewed the licensee's program for control of radioactive materials and contamini. tio Monitor alarm methodology, func+1onal tests and calibration procedures were reviewed by the inspectors for whole body friskers, portal

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monitors, and certain portable instrumentation. Required tests and calibrations appear to be performed in accordance with station procedures and manufacturer's recommendations. Alarm setpoints for the whole body friskers are consistent with guidance contained in IE Circular 81-07 " Control of Radioactively Contaminated Material" (5000 d am/100 cm') . Whole body friskers and portal monitors are functionally c1ecked weekl Identification, dose evaluation, and reporting of personnel contamination events (PCEs) appear to be done in accordance with procedural requirements. No significant changes have been made to skin dose calculational methodology, which had previously been evaluated by the inspector and found acceptable. As with external exposure (section

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4), the licensee's PCE goal was revised owing to emergent work. To date, 110 PCEs have been recorded which is below the goal of 118 for 199 l I

While touring the plant, the inspector noted problems in labeling and I storage of tools with fixed contamination in the old machine shop, and a

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poorly labeled 0.5 curie )olonium-beryllium neutron source stored in the old calibration shack. T1e calibration shack is normally locked and the keys controlled by the RP supervisor, who also maintains a logbook ,

documenting radioactive source type, activity, and location. Because '

adequate controls are maintained over the source, labeling is not required under the licensee's procedure or 10 CFR 20.204(f)(3)(vi).

The licensee did agree, however, that the source label should be replace Contaminated tools stored in the old machine shop were labeled as radioactive material, but many of the labels were in poor condition and did not appear to document contamination levels as required by administrative procedure 5.11. " Radioactive Material Control."

Further, these tools appeared to be indiscriminately mixed with clean tools. Failure to adhere to a radiation controls procedure is a violation of technical specification 6.11. This violation is categorized at Severity L.evel V and is not being cited because the criteria specified in Section Vll.B.1 of the " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C) were satisfied. This area is not well frequented by plant workers and is surveyed on an as needed basis, also workers appeared to be cognizant of the radiological concerns. The licensee will replace the degraded labels and evaluate methods to improve tool control. This matter will be reviewed by the inspector during future inspections (IFI No. 50-155/92026-02(DRSS)).

One non-cited violation was identifie . Imolomentation of the Revised 10 CFR Part 20 Training has been provided to plant staff on the revised Part 20 and a videotape has been developed for use in Nuclear General Employee Training (NGET). Station documentation affected by the change l

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have already been developed and are in the (procedures,RPplan,etc)WhiletheNRCdoesnotrequireadherenceto process of final revie revised Part 20 requirements until 1994, the licensee plans to begin following the new regulations on January 1, 199 . Insoection followuo items flFI)

Ins)ection followup Items (IFI) are matters which have been discussed wit 1 the licensee, will be reviewed further by the inspector and which involve some action on the part of the NRC, licensee or both. IFis are discussed in sections 2 and . Exit-Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on December 4, 1992. One cited and two non-cited violation were identified during this inspection. No-documents were identified as proprietary by the licensee. The following matters were specifically discussed by the inspector:-

o Measurement of stack flow rate (section 2)

o ALARAcommitteecharter(sectionSa)

o Source term reduction initiatives (section Sc)

o Licenseeassessmentofairbornehazards(section6)

o Storage-and labeling of contaminated tools (section 7)

o- Labeling of radioactive neutron source (section'7)

o Implementation.of the new Part 20 (section 8)

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