IR 05000155/1997011
| ML20211J745 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/06/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211J727 | List: |
| References | |
| 50-155-97-11, NUDOCS 9710080283 | |
| Download: ML20211J745 (18) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli
. Docket No: 50-155 License No: DPR-06 Report No: 50-155/97011(DRS)
Licensee: Consumers Power Company Facility: Big Rock Point Nuclear Power Plant Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: September 2 - 5,1997 Inspector: W. G. West, Radiation Speclatist Approved by: G. Shear, Chief, Plant Support Branch 2 DMslon of Reactor Safety 9710080233 971006 PDR ADOCK 05000155 G PDR
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EXECUTIVE SUMMARY Big Rock Point Nuclear Power Plant NRC Inspection R3 cort 50-155/97011 This inspach n included various aspects of the licensee's Chemistry and Radiation Protection Program s T ie inspection focused on evaluating aspects of licensee performance which would be applicaLl0 during the plant's decommissioning phase. The areas reviewed were:
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Radiological Controls for the Reactor Head Detensioning and Removal Jobs
. Use of Electronic Dosimetry
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General Radiation Protection (RP) Practices
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Plant Housekeeping and Radiological Posting
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Effluent Releases and Offsite Doses
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Process and Effluent Radiation Monitors
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Chemistry Laboratory Materiel Condition
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Radiation Protection and Chemistry Management and Staff Changes
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The following conclusions were reached in these areas:
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Radiological controls during the performance of the reactor head detensioning and removal jobs weie generally satisfactory. However, the inspector identified a violation in which a maintenance worker was lying down in a contaminated area. This incident indicated inadequate worker attention to RP, as well as poor RP staff oversight of the job (Section R1.1).
. The inspector reviewed several recent licensee-ldentified instances of? lant workers entering the Radiologically Controlled Area without functioning electronic dosimetr Due to the station's prompt identification and comprehensive corrective actions in response to these events, these examples constituted a Non-Cited Violation (Section R1.2).
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In general, radiological areas were property posted and appropriate boundaries maintained. The inspector identified one concem regarding the station RP practice of posting signs for radiological areas only at entry / exit points to those areas, rather than posting signs along boundaries of these areas so that their status can be seen from any approach point. Station housekeeping was effective in maintaining plant areas free of unnecessary materials and debris (Section R1.3).
. Radioactive effluent releases and associated dose to the public were well below the regulatory limits (Section R1.4).
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Process and effluent radiation monitors were operable and performing well. Instrument source checks, functional tests, and calibrations were performed by plant personnel in a timely and effective manner (Ssation R2.1).
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Chemistry laboratory analytical equipment was maintained operable and in good condition (Section Re.2).
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Extensive management and staff changes had been and were being made in the plant's radiation protection and c.hemistry programs. These changes appeared cppropriate considering the plant's transition into decommissioning operations. The qualifications of incoming personnel were appropriate for their positions and responsibilities (Section R6.1).
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Report Details R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Radiological Controls for the Reactor Head Detensioning and Removal Jobs Insoection Scooe (IP 83750)
The inspectors (the Big Rock Point NRC resident inspectors assisted in this inspection activity) observed the reactor head detensioning and removal jobs on the refueling floo Specifically, the inspectors reviewed the wearing of personal comamination clothing, the use of dosimetry, the performance of the jobs from a contamination control and dose reduction standpoint, and Radiation Protection (RP) job oversigh Observations and Findings The inspectors observed part of the reactor head detensioning operation, as well as all of the reactor head removal operation. Workers appeared to be dressed out properly and all involved individuals (workers and RP technicians) paid careful attention to the taping of gloves and booties and the proper placement and attachment of dosimetr The refueling floor south of the crane tracks was designated as a contaminated area and controlled as such, with a clean area set up on the north side of the refueling floor for observation of activities by supervisors and foreign material exclusion personne This clean area was regularly mopped down to maintain its clear status. During performance of these jobs, there were approximately four to eight traintenance workers and four RP technicians dressed out, as well as several supervisors standing in tha clean are Just before the start of the detensioning operation on September 2, the inspectors noticed that one of the maintenance workers was lying down in the contaminated area on the refueling floor. The individual was fully dressed out and located in a designated low dose rate area. The inspectors pointed out the prone worker to the radiation protection supervisor on shift and asked whether the individual was injured or had some other problem which would force him to lay down. The radiation protection supervisor promptly informed the maintenance supervisor of the situation, who then had the worker stand up. The worker then informed the inspectors that he was neither injured nor sleeping and that he had laid down because he had been waiting for some other workers to complete a task for over an hour. Further licensee evaluation determined that the individual had been lying down for approximately five minutes. Prior surveys of the area indicated that smearable contamination at the point where the worker was laying was approximately 4,000 dpm/100 cm2 before any work was done on the refueling floor. It is likely that since some work had already been done on contaminated components in the area and no decontamination activities had been performed, contamination levels were at least as high as those indicated in the survey map Though in this case no detectable spread of contamination or intake occurred, this type of 20 tion increases the probability of their occurrence. The inspectors weie especially
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i concerned that this incident was not prevented by the high level of RP technician (and supervisor) presence on the refueling floo The inspectors discussed this incident with the radiation protection manager and the piant manager, both of whom indicated that this behavior was not consistent with management expectations for worker practices. At the time of the exit meeting. plant management had counseled the worker and his supervisor and were planning on sending a notice to plant workers defining the station policy on resting in contaminated ,
areas. Both the individual and his supervisor were present at the exit meetin l Technical Specification (TS) 6.11 requires, in part, that procedures for personnel radiation protection be sdhered to for all operations involving personnel radiation ,
exposure. TS 6.1 applies to Administrative Procedure 5.5, * Radiation Work Permit," )
(Revision 12), which instructs workers to not unnecessarily contact contaminated j surfaces with their bodies, tools or equipment, and to not disturb such surfaces, which '
could spread contamination or create airbome radioactivity. Therefore, lying down in a contaminated area is a violation of TS 6.11 (50155/97011-01).
The inspectors also noted that the instructions in the pre-job briefing for the worker's radiation work permit (RWP# 97-1085) indicated that, "Any delays (wait for tools, shift change, etc) of greater than 10 minutes should be waited out - off the deck." Though it was difficult for the worker to determine how long he would be waiting, the fact that he had to wait in a contaminated area (and a radiation area) for over an hour for his work task to begin calls into question the adequacy of job planning for the detensioning operatio No prob! ems were noted during the performance of the head removal job. The reactor vessel head was stored in Room 444 near the refueling deck, while the shield plug was stored on the main floor of containment near the equipment hatch. The area around the plug was posted properly as a High Radiation Are Conclusions in general, radiological cor trols during the performance of the reactor head detensioning and removaljobs were satisfactory. However, the inspectors identified one violation of Technical Specifications concerning a maintenance worker lying down in a
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contaminated area. This incident indicated that worker attention to radiation protection (especially in the area of contamination control), as well as RP oversight of jobs, remained a problem for the statio R1.2 Use of Electronic Dosimetry IDSpection Scoce (IP 83750)
The inspector reviewed station employee use of electronic dosimetry through observation of employees entering and exiting the radiologically controlled area (RCA),
through personnelinterviews, and by review of related condition reports (CR's). In
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addition, the circumstances surrounding three recent instances where individuals entered the RCA with their electronic dosimeters (ED's) on " pause" were reviewed, b. Observations and Findings in May 1997, there were three instances where indiv! duals entered the RCA with their ED's on " pause," which prevents these devices from rneasuring dose rate or accumulated dose, or from performing their alarm functions. In the first incident, on May 6,1997, a chemistry technician performed high radiation chemistry sampling of reactor coolant and associated laboratory work with his ED on pause. The chemistry technician realized that his ED had been on pause when he exited the RCA and attempted to sign off his RWP. He promptly made a dose assessment and reported the incident to dosimetry personnel, who initiated a condition report (CR# 97-301), all per procedure, The licensee determined that the cause of the incident was that the individual had forgotten that he had logged out of an RWP earlier in the day and thus assumed that his ED was still active, as well as poor self-checking of dosimetry, in the second incident, on May 18,1997, a shift supervisor on requalification watch entered the RCA without completely 'ogging onto the ED computer system and remained therr. for approximately thirty minutes. The individual resti.:ed that his ED had been on pause when he exited the RCA and attempted to sign off his RWP. After the event, the individualinitiated a condition report (CR# 97-318). The licensee determined that the cause of the incident was that the individual had removed the ED too quickly from the ED computer for it to be activated and that the individual exhibited inadequate self-checking of this dosimetry, J
In the third incident, on May 29,1997, a part-time reactor engineering technical analyst entered the RCA with her ED on pause and remained there for approximately ten minutes. The licensee determined that the individual had removed the ED too quickly from the ED c:mputer for it to be activate The licensca determined that the root cause of all three events was the same; individuals (or other personnel) failed to check the status of their ED's both before their entry into the RCA and during their presence in it. The station's corrective actions included:
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The individuals involved and their supervisors were counseled by RP personnel;
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The Chemistry and Health Physics Manager reviewed the incidents with his staff;
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Station management began revoking RWP authorization for everyone daily so 1 that employees would have to reread their RWPs and answer RP technician questions in order to enter the RCA (this was a temporary change);
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The plant manager sent a memorandum (dated May 30,1997) to all plant staff noting the recent events and instructing plant staff to self-check their ED's regularly and to be more radiologically aware;
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Radiation protection personnel installed a swing-gate with an audible alarm at the main RCA entry point to remind individuals that they are entering the RCA and should check their dosimetry; and
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Plant staff rewired the devices which activate the ED's so that they would alarm if an ED was removed before it had been completely activated / rese These corrective actions appeared to be effective and appropriate. The inspector noted that during all of his own entries into the RCA, as well as during those entries by others which he observed, RP technicians at the RCA entrance queried Individuals as to the state of their ED's and asked questions related to the RWP's, in the abovo incidents, the individuals involved were performing relatively low-dose and low-risk jobs. Thus, the actual danger to the individuals was minimal. However, if an individual who was performing a high dose or high dose-rate job were to have this ,
problem, the potential for an overexposure would be much greater. The inspoctor discussed the ED issue, and these associated safety concerns, with RP and station management, who expressed their understanding of the problems and recognition of their safety significanc in addition to these three recent events, the station had identified eight similar instances in 1996, the last event occurring on August 16,199A. These events were the subject of several station audits and trend reports in which the licensee recognized an increasing problem and took steps to correct it. After the August 1996 event, RP management established the expectation that an RP technician would be present at the RCA entry point as much as pos m ,ein October 1996 the RP Manager directed that an RP technician would be ' , ed to this location during normal working hours to assist station personnel wh,, - ;s, radiological conditions, RWP's, and ED's. Between the August 1996 event and tne May 1997 event, this and other corrective actions appeared to be effective, as there were approximately 22,000 entries into the RCA without erro The inspector determined, through analysis of the circumstances of both the recent and past events, that the recent events did not stem from a failure of the licensee to adequately address the root causes of the past event TS 6.11 requires, in part, that procedures for personnel radiation protection shall be adhered to for all operations involving personnel radiation exposure. Administrative Procedure AP 5.7, " Personnel Dosimetry and Dose Control," Step S.1.2 (Secondary Dosimetry), stated that electronic dosimeters are required for those workers issued a thermo-lumiri escent dosimeter (TLD) and having RWP authorization. The Big Rock Point Radiation Safety Plan, Revision 15,Section V, Part 1, item b.3, states that,
" Direct-reading or electronic dosimeters should be read or zeroed prior to their use and read periodically thereafter by the wearer." These three examples of a failure to enter the RCA with a working ED constitute a single violation of TS 6.11. This non repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-155/97011-02). Conclusions Several recent instances of plant workers entering the RCA without functioning electronic dosimetry constitute a violation of plant procedures. This violation is being
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classified as a Non-Cited Violation due to the station's prompt identification and comprehensive corrective actions in response to these event R1.3 Walkdowns within the Radioloalcally Controlled Area insoection Scooe (IP 83750)
The inspector conducted walkdowns of various areas within the RCA, including the refueling floor and the shield plug laydown area, as well as various locations in the containment sphere, turbine deck, and radwaste processing and sampling areas. In addition, the inspector interviewed RP staff regarding radiological conditions and controls within the plan Observations and Findinas During the plant walkdowns, the inspector verified the adequacy of radiological posting and labeling, as well as the demarcation of associated boundaries, in general, areas were properly posted and appropriate boundaries maintained. For example, the inspector observed an RP technician survey the area around the shield plug (a posted High Radiation Area) to confirm boundary placement and noted that the survey and boundary placement were performed properly. The inspector also noted that station housekeeping appeared effective in maintaining plant areas free of unnecessary materials or debris, especially considering the outage status of the plan One concern was identified with regard to the station RP practice of posting signs for radiological arees only at entry / exit points to those areas, rather than posting signs elong boundaries of these areas so that their status can be seen from any approach point. This practice was seen at several plant radiological boundaries. One example of this practice was the posting of the refueling deck as a contaminated area during defueling operations. Specifically, the inspector noted that the north side of the refueling deck, which was designated as a clean area (also a posted Radiation Area), was separated from the contaminated southern portion of tha refueling deck by a painted yellow-and-magenta hashed line on a ledge approximately four feet high along the vane track. This boundary extended approximately 50-75 feet along this ledge, yet had no
" Contaminated Area" signs along its length to identify its purpose. On the far east side of the boundary was a change-out area for deck workers and the access point for those workers, wh!ch had a swing gate posted with the correct sign; however, this entry was not visible to personnel approaching the boundary or observing refuel floor work from most of the north side of the deck. The possibility of worker confusion over the identity of plant radiological boundaries would likely be increased in view of the large number of
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contract personnel (who are not as familiar with station areas or non-standard posting l guidelines)in the plant during the decommissioning phase of plant operations. The
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inspector communicated this concern to the radiation protection manager and plant manager. The radiation protection manager expressed concern about overposting of areas and the potential for worker desensitization to postings, but indicated that the RP department would evaluate their posting policy to determine whether additional postings would be appropriat i
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' Conclusjong The inspector found that, in general, areas were properly posted and appropriate boundaries maintained. However, onc concern was identified relating to the station RP practice of posting signs for radiological areas only at entry / exit points to those areas, rather than posting signs along boundaries of these areas so that their status can be
, seen from any apprcach point, it was noted that station housekeeping appeared l
effective in maintaining plant areas free of unnecessary materials and debris, especially considering the outage status of the plan R1.4 Plant Effluent Releases and Offsite Doses (IP 84750)
The inspector reviewed plant gaseous and liquid effluent releases for 1997, as well as calculated offsite deses from those releases. For calendar year 1997 (up to August 21),
the station had released 2060 Cl of gaseous effluents. Thus, the average effluent release rate for 1997 to date was approximately the same (down 8%) as that of 199 Total liquid effluents totaled 11.2 mCl from three planned chemical tank releases. The inspector established that for the period studied, gaseous and liquid offsite doses were
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calculated using Offsite Dose Calculation Manual (ODCM) methodology. Radioactive releases and dose to the public from the releases were well below the regulatory permissible limits R2 Status of RP&C Facilities and Equipment R Process and Effluent Radiation Monitors (IP 8475D)
The inspector reviewed a sample of source check and functional check procedures and ,
records for the TS-required process and effluent radiation monitors, in addition, interviews with cognizant chemistry personnel regarding the operability and performance of the monitors were conducted. Also, a walkdown of the plant stack wide range gas monitor and flow instruments was complete The inspector found that all of the TS-required process and effluent radiation monitors were operable and were performing well. Various source checks, functional tests, and calibrations indicated that plant personnel performed these TS-required activities in a timely and effective manner. No discrepancies or problems with the performance of these activities were identifie R2.2 Chemistrv Laboratorv Analvtical Eculoment Scoce (IP 84750)
The inspector reviewed the material condition of chemistry laboratory analytical equipment through a walkdown of the chemistry laboratory. In addition, a review of the projected chemistry activities and equipment needs for the decommissioning phase of the station's operation was conducted through interviews with chemistry personne l l
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The inspector noted that laboratory housekeeping was adequate and that laboratory instruments appeared to be in working order. A review of the performance and operability of the following laboratory instruments was conducted:
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Dionex DX-1000 lon Chromatograph
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Sybron Infrared Total Organic Carbon Analyzer
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Bauch & Lomb Spectrophotometer (for silicas)
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Perik & Elmer Atomic Absorption Spectrophotometer '
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Nuclear Data NO-6685 Gamma Spectrometer
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Canberra Gamma Spectrometer
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NMC PC-5 Windowed Proportional Counter
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Eberline SAC-4 Alpha Counter (Zine Sulfide)
Conductivity Analyzers
. pH Meters No problems were noted with the lat' oratory analytical equipmen A review of the effects of decommissioning on chemistry equipment needs and chemistry activities with the acting chemistry supervisor was conducted. The inspector determined that the analytical equipment would still be utilized for normal operational sampling, such as effluent sampling; spent fuel pool water analysis; and analysis of smears, filters, cartridges, etc. However, much of the chemistry analytical work is not applicable during decommissioning, such as reactor coolant sampling, off-gas sampling, et Conclusions The inspector found that chemistry laboratory analytical equipment was maintained operable and in good condition. Also, though the volume of chemistry work will decrease during the decommissioning phase of plant operation, the equipment will still be utilized for routine chemistry operational task R6 RP&C Organization and Administration R Manaaement and Staff Chanaes due to Plant Decommissionina_ Insoection Scoce (IP 83750. IP 84750)
The inspector reviewed the management and staff changes, particularly in the radiation
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protection and chemistry areas, that were being made as a result of Big Rock Point's-entry into decommissioning. This review included discussions with plant management and waf i
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l Observations and Findinos The inspector rev!ewed several revised plant organizailon charts and noted that the RP management structure had been modified to concentrate on arear of high RP involvement in decommissioning and disassembly operations. The current RP manager (RPM) was being retained, though his title was changed from Chemistry / Health Physics Manager to RP/ Environmental Manager. Previously, the RP&C department had consisted of four functional areas reporting to the RPM: Radiation Protection, Work Control (including Al. ARA oversight), Radwaste Shipping, and Chemistry / Dosimetr Additionally, a health physics technical consultant also reported directly to the RP The revised organization separated the Chemistry / Dosimetry section into two separate entities: Environmental and Dosimetry. Also, an RP assessor had been added to serve in an auditing function and report directly to the RPM. A senior reactor operetor had also been added to the work control section in a supervisory capacity to assist in the identification of jobs which would require increased RP focus and serve as a technical consultant to the departmen In addition to the management and organization changes in the RP department, the plant had added 14 new employees to the department, including a new Doelmetry Supervisor and Environmental Supervisor. The inspector reviewed the resumes of these new supervisors and select new technical staff and found that their qualifications were appropriate for their assigned positions and responsibilities. Though the incoming Environmental Supervisor had very little experience in radiochemistry and did not meet the current plant requirements for chemistry supervisor (ANSI N18.1-1971), RP managemont pointed out that a senior chemistry technician with extensive rac"ochemistry experience was and would be acting in the role of chemistry supervisor for decommissioning operations. The reduction in the size of plant chemistry staff (from four full-time employees to one full time and one pcrt-time employee) appeared commensurate with the reduced chemistry responsibilities and activities during decommissioning.
' Conclusions The inspector found that extensive management and staff changes had been and were being made in the plant's radiation protection and chemistry programs. These changes appeared appropriate considering the plant's transition into decommissioning operations. The qualifications of incoming supervisory personnel were appropriate for their assigned positions and responsibilitie R8 Miscellaneous RP&C lssues (IP 92904)
The inspector reviewed all of the radiation protection and chemistry open items for the station. Items where appropriate changes or corrective actions had been completed on the part of the licensee were close R (Closed) Follovi-Uo item 50-155/95008-03: Multiple concems with SFP HX cleaning jo This item included two prob' ems with overalljob performance by health physics
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personnel. The first problem involved unnecessary dose received by personnel staging and un-staging the spent fuel pool (SFP) heat exchanger (HX) room for contaminat9d work when the job was not ready to start. The second case involved the staging for the third time that SFP HX cleaning was to take place. The staging for this wd was
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deficient in that excessive materials were used and screen doors designed to block large materials were left open in an area where ihe material could possibly have blocked a post incident suction strainer if it had become dislodged. The inspector reviewed the licensee's corrective actions, which included the following:
a plant management discussed the importance and proper conduct of job planning and pre-job briefings with RP personnel,
. plant personnel placed signs on both sides of the screen doors to inform workers of the necessity of keeping the doors closed when not in use and of minimizing materials brought into the area, and
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plant management sent a notice to plant employees (dated October 11,1095)
informing them of the importance of material control around the suction strainer The inspector also discussed the recent performance of HP Job oversight and planning with the site NRC resident inspectors and RP management and found that two SFP HX jobs were performed in the last two months without beident and appropriately, according to the resident inspectors. The inspector concluded that the licensee's corrective actions had been appropriat R8.2 (Closed) Follow Uo item 50-155/95010-02; Resin and water on floor of resin tank roo This item concerned the presence of approximately six inches (depth) of water and resin in the resin tank room which had overflowed the resin disposal tank. The causes of the overflow wero a failure to ensure adequate space in the resin disposal tank prior to resin transfer and a plugged dewatering drain in the resin disposal tank. The licensee wrote a condition report on the spill on August 9,1995. The operations department subsequently c' eared the blocked drain, removing a large portion of the spill, and the licensee decontaminated the floor area. The licensee's corrective actions included revising plant procedures SOP-3, SOP-11, and SOP-15 to require that the tanks in question are dewatered before resin transfers and that the tank levelis checked before and during these transfers. This event; es well as three other related events which occurred shortly thereafter (see Follow-Up Item 50-155/95010-03 below), were discussed in Inspection Report 50-155/95011. Since these events, no other problems have been noted by the licensee regarding resin disposal tank overflows. The inspector ,
found that the licensee's corrective actions had been appropriate and effectiv '
R8.3 (Closed) Unresolved item 50-155/95010-03: Fluid from primary transfer piping to secondary enclosure This unresolved item dealt with events on August 29, September 2, and September 13,1995 involving resin and water control problems during work on related systems. The details d these events, as well as most of the licensee's corrective actions and NRC assessment of those actions, was discussed in inspection Report 50-155/95011. Licensee technical staff indicated that in addition to the actions taken in late 1995 and as a result of the issues surrounding Follow-Up Item 50-155/95010-02 (see above), a new transfer pipe was installed near the end of 1996
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which should prevent leakage during resin transfer operations. This action, as well as the corrective actions for Follow-Up Item 50155/95010-02, appear to have been effective in preventing recurrence of these problem R8.4 (Cjosed) Follow-Uo item 50-155/96003-03: FHSR update to include TS exemption This Final Hazards Safety Report (FHSR) item, discussed in inspection Report 50-155/96002, pertains to a Section 12.1.3 requirement that all work in radiation areas and all entries to high radiation, contamination, and airbome radioactivity areas requires the use of an RWP. Plant Technical Specifications Section 6.12.1, however, allowed an exception to this policy in cortain circumstances. The inspector found that the licensee had added text to FHSR Section 12.3.1 to alleviate this ditcrepancy and, when asked about Section 12.1.3, RP staff informed the inspector that the TS exceotion would only be used in cases of emergency and, therefore, the design document (FHSR) reflected the normal operating policy of the plant. The corrective action was satisfactor R8.5 (Closed) Viol 6 tion 50-155/97002-04: Failure to follow RP procedures outside RC This violation involved the discovery of some contaminated lead sheets outside the RCA, near the plant loading dock. The inspector interviewed the RPM regarding this event and found that the licensee's corrective actions for this violation included RP management's insistence on more careful surveying of items leaving the RCA for RP technicians and increased training focus on material control. The licensee nor the NRC resident inspectors had identified any uncontrolled contaminated or radioactive materials outside the RCA since this event. The inspector also oerformed a complete walkdown of all outdoor site areas around the station with a survey meter and found no uncontrolled radiological materials outside the RCA or designated radioactive materials storage area R8.6 (Closed) Violation 50-155/96004-01: Failure to follow requirements of RWP and radiological postings. This violation concerned the entrance of a worker into a contamination area without required anti-contamination clothing, in Inspection Report 50-155/96004, it states that, " licensee management did not clearly communicate to all radiation workers that the yellow swing gates were radiological boundaries following previous worker confusion on the use of these gates." Though this violation involved worker confusion over radiological postings, this confusion did not result from inadequate posting or underposting. The station's corrective actions included increased worker training on the plant's posting practices and respect for radiological boundarie These corrective actions appeared appropriate and effectiv R8.7 -(Closed) Violation 50-155/96010-04: Poor contamination control practices. This violation concerned an August 5,1996 event in which two workers unnecessarily spread contamination on themselves and previously uncontaminated portions of the plan RWP-required RP oversight of the job was not performed. Because this violation exhibited similar root causes (poor radiation worker practices and inadequate RP oversight) as the September 2,1997 event with the maintenance worker lying down in a contaminated area (see Section R1.1), this item is being supplanted by Violation 50-155/97011-01 from this inspection.
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R3.8 (Closed) Violation 50-155/96011-0 i: Failure to adequately post and survey rad;ological area. This violation concerned several ins %nces in late 1996 involving improper or inadequate radiological postings and labeling, as well as an unrestricted release of radiological ma'erial. Specifically, the plant's resin shed was not posted as a High l Radiation Area and Contaminated Area as requiiad, several boxes were improperly
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labeled, and a contaminated truck was released from ihe RCA. The plant's corrective actions included coirection of the individual occurrences, revision of applicable station procedures to verify labeled information vaith actual readings, and edditional training of station RP technicians. The inspector evaluated these corrective avions and found that they appeared to be effective. The inspector also performed a complete walkdown of all outdoor sN areas around the station with a survey meter and found no posting or labeling deficiencies or uncontrolled radiological materials outside the RCA or designated radioactive materials storage area R8.9 {Ocen) Violation 50-155/970C5-01: Two examples of a failure to peisrm adequate evaluat!on. This violation involved three events in early 1997: a tour of a hign radiation area by a qualified shift supervisor and a senior radiation protection technician under abnormal radiological conditions; the spread of contamination throughout the turbine building during radioactive waste processing activities; and the entry into a high radiation area by a worker who had not completed the required training for access. Though the licensee's documented corrective actions cppeared appropriate, this item will remain open pending resolution of the station's radiation worker practices and HP oversight problems (see Section R1.1).
R8.10 (Ocen) Violation 50-155/97005-02: Two examples of a failure to follow procedural requirements. This violation involved the same ihree events in early 1997 as Violation 50155/97005-01 (above). This item will also remain open pending resolution of the statior radiation worker practices and HP oversight problems (see Section R1.1).
R8.11 (Ocen) Violation 50-155/97005-03: Failure to perform safety evaluation. This violation ir,volved the same three events in early 1997 as Violation 50155/97005-01 (above).
This item will also remain open pending resolution of the station's radiation worker practices and HP oversight problems (see Section R1.1).
X1 Exit Meeting Summary Tt'e inspector presented the inspection results to members of licensee management during an exit meeting on September 5,1997. The licensee did not indicate that any materials examined during the inspection should be considered proprietar . - . ___
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PARTIAL LIST OF PERSONS CONTACTED Licensee W. Barnshaw, Assessment Supervisor C. Barsey, Chemistry Supervisor J. Boss, Operations Manager / Acting Plant Manager -
W. Brunkow, ALARA Coordinator O. Hale, Health Physics Auditor D. Hice, Maintenance Manager T. Mosley, Work Control Supervisor K. F3llagi, Chemistry / Health Physics Manager K. Poweru, Plant General Manager J. Werner, Radiation Protection Supervisor NflC R. Leemon, Senior Resident inspector, Big Rock Point C. Brown, Resident inspector, Big Rock Point PROCEDURE INSPECTION S USED
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IP 83750: Occupational Exposure IP 84750: Radioactive Waste Treatment, and Effluent and Environniental Monitoring IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Daened 50-155/97011-01 VIO Worker lying down in contaminated are /97011-02(a,b.c) NCV Three examples of workers entering RCA with ED's on
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Closed 50-155/95008-03 IFl Multiple concerns with SFP HX cleaning jo /95010-02 IFl Resin & water on the floor of the resin tank roo /95010-03 IFl Fluid from primary transfer piping to secondary ei,alosur /96003-03 IFl FHSR update to include TS exemption _ _ _ _ _ _ _ _ _ _ _ . ._
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50 155/96004-01: VIO Failure to follow requirements of RWP & rad posting /96010-04 VIO Poor contamination control practice /90011-01 VIO Failure to adequately post and survey a radiological area, 50-155/97002 04 VIO Failure to follow RP procedures outside the RC Discussed
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50-155/97005-01 VIO ' Two examples of a failure to perform an adequate evaluation, 50-155/97005-02 VIO Two examples of a failure to follow procedural ,
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50 155/97005-03 VIO Failure to perform a safety evaluation.
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LIST OF ACRONYMS USED ALARA . As Low As Reasonably Achievable CR Co_ndition Report DRS Division of Reactor Safety ED- Electronic Cosimeter FHSR Final Hazards Safety Report HX Heat Exchanger IFl Inspection Followup Item IP Inspection Procedure NCV Non-Cited Violation NRC Nuclear Regulatory Commission-ODCM- Offsite Dose Calculation Manual PDR Public Document Room RCA Radiologically Controlled Area RP Radiation Protection U RP&C Radiation Protection & Chemistry
- _ RPM Radiation Protection f.4anager RWP Radiation Work Permit SFP Spent Fuel Pool TLD Thermo-Luminescent Dosimater TS Technical Specification
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r- PARTIAL LIST OF DOCUMENTS REVIEWED i
Inspection Procedure 83750 inspection Procedure 84750 inspection Procedure 92904 NRC Inspection Report No. 50-155/95008 NRC Inspection Report No. 50-155/95010 NRC Inspection Report No. 50 155/96003 NRC Inspection Report No. 50-155/96004 NRC Inspection Report No. 50-155/96010 NRC Inspection Report No. 50-155/96011 NRC Inspection Report No. 50-155/97002 '
NRC Inspection Report No. 50-155/97005 BRP FHSR Rev. 6 Section 12.1.3 anct Section 12. i BRP Technical Specifications 6.11. " Radiation Protection Program" BRP Radiation Safety Plan (Rev.15)
BRP Annual Radioactive Effluent Release Report- 1996 BRP Corrective Action Quarterly Trend Analysis Report - First Quartar 1996 ANSI N18.1 - 1971 NPAD Field Monitoring Report dated May 21,1997 (FM-B-059)
Letter dated June 18,1997 w/ attachment from Robert J. Addy, BRP Plant Manager to NRC -
" Response to apparent violations b Inspection Report No. 50-155/97005(DRS)."
Letter dated June 18,1997 from K. Powers, BRP Plant Manager to NRC " Notification of Big Rock Point Nuclear Plant Shutdown for decommissioning on August 30,1997."
Letter dated June 26,1997 from K. Powers, BRP Plant Manager to NRC " Big Rock Point Plant - Certification of permanent cessation of operation."
Memorandum dated May 8,1997 from D.W. Parish to T. Popa "ED Event 5/6/97" RWP No. 97-1085 w/ pre-job briefing checklist RWP No. 97-0008 w/ attachment BRP Procedures:
AP 5.5 (Rev.12)" Radiation Work Permit" AP 5.7 (Rev.16)" Personnel Dosimetry and Dose Control"
- AP 5.8 (Rev.10)"High Radiation Area Key and Access Control" AP 5.23 (Rev. 4)" Merlin Gerin Electronic Dosimetry System" RP-31 (Rev. 50) " Personnel Dosimetry" BRP Condition Reports:
C-BRP 95-523," Resins on Disposal Tank Room Floor" C-BRP-95-619, " Resin Transfer Line Failure" C-BRP-97-301, " Worker Exits RCA with ED on Pause" C-BRP-97-318," Entering the RCA with ED on Pause"
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