IR 05000155/1998002

Insp Rept 50-155/98-02 on 980203-0406.No Violations Noted. Major Areas Inspected:Licensee Mgt & Control,Decommissioning Support Activities,Spent Fuel Safety & Radiological Safety

ML20217D149
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/21/1998
From:	Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217D127	List: IR 05000155/1998002 ML20217D122
References
50-155-98-02, 50-155-98-2, NUDOCS 9804240228
Download: ML20217D149 (24)

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i U.S. NUCLEAR REGULATORY COMMISSION l

REGION lli l

Docket No.: 50-155 j l

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License No.: DPR-6 )

I Report No.: 50-155/98002(DNMS)

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Licensee: Consumers Energy Company I'

Facility: Big Rock Point Nuclear Power Plant

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Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: February 3 - April 6,1998 Inspectors: R. J. Leemon, Senior Resident inspector C. E. Brown, Resident inspector R. B. Landsman, Project Engineer P. W. Harris, License Project Manager D. W. Nelson, Health Physics inspector Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety l

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i 9804240228 980421 PDR ADOCK 05000155 G PDR

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l EXECUTIVE SUMMARY Big Rock Point Nuclear Power Plant NRC Inspection Report 50-155/98002(DNMS)

This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, spent fuel safety, and radiological safet * Overall, the licensee's performance in the response to the discharge canal radiation monitor alarm and the steam drum area washdown (with excellent as-low-as-reasonably-achievable (ALARA) discussion) were good; however, operators snagging a fuel handling tool on the spent fuel pool (SFP) rack and operators inadvertently de-energizing the radio gas and effluent monitor unit were examples of poor performanc Facility Manaaement and Control e Changes in the shift complement which reduced the shift crew composition by one control room operator and one auxiliary operator were within the current Technical Specification (TS) requirements for a plant in cold shutdow * A lower radiation protection (RP) supervisor-to-worker ratio should improve the effectiveness of the RP organization by increasing control and quality of RP activities performe j e The monies spent on decommissioning activities were within the scheduler and expenditure requirements of 10 CFR 50.8 e No unresolved safety questions were identified for procedures and modifications reviewed by the Plant Safety Review Committe * The Defueled Security Plan was submitted to the NRC for review. A zircaloy oxidation analysis is pending the results of which will affect this submittal. This is an inspection followup ite * On March 31,1998, the Annual Emergency Preparedness exercise for 1997 was successfully complete e The licensee completed, approved, and implemented revisions to all chapters of the l Updated Final Hazard Summary Report on March 13,1998, for the permanently defueled I plan e The material integrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained. Plant housekeeping and fire protection were generally goo i

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Decommissionina Support Activities

• The time for the SFP to heat from 80 F to 150 F is now 8.4 days which is greater than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assumed in the proposed defueled TSs. As the decay heat in the fuel decays away, there is more time for the licensee to respond to loss of cooling to the spent fuel poo e inadequate review of electrical drawings for tagging of the opening of Bieaker Y-1, followed by a control operator's inattention to control board indications during hourly readings resulted in the radio gas and effluent monitor equipment unknowingly being out I

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of service for about 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Spent Fuel Safety l

I e The safety of the fuel in the spent fuel pool was maintaine e A fuel handling tool caught on the spent fuel rack and sprung-free after an operator failed to control the fuel handling tool and slack in the winch cable, resulting in minor damage to the fuel handling too * A licensee audit of the quality assurance (QA) program of the dry fuel storage cask vendor identified some fundamental weaknesses which need to be addressed to preclude problems that other storage cask vendors have had with cask system design and fabricatio Radioloaical Safety

• The Annual Occupational Exposure Report was submitted to the NRC one day lat * The radiological and asbestos cleaning of the recirculation pump room was well planned and briefed. Health physics technicians and workers used excellent ALARA practices during the process. The washdown resulted in a large reduction in general area dose rates and contamination level * Documentation of Nuclear Performance Assessment Department (NPAD) followup of findings regarding labeling of radioactive materials and/or containers housing radioactive materials and poor radiological safety practices by workers appeared to be wea Initiation of a Condition Report (CR) to address this weakness appeared to be a good first step in resolving the issu * An incident involving shipment of mercury to the GTS/Duratek waste processing facility demonstrated significant weaknesses in the licensee's radioactive and hazardous waste shipping progra *

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Report Details Summary of Plant Activities During the inspection period, the size of the operations shift crew was reduced, the radiation protection department was reorganized, the revised Updated Final Hazard Summary Report (UFHSR) was issued, and the Defueled Security Plan was submitted to the NRC. Also, tests on the spent fuel pool (SFP) heatup rate were conducted, the stack gas radiation monitor was inadvertently de-energized, safety of the fuel in the SFP was maintained, and operators snagged a fuel handling tool on the SFP racks. The licensee declared an unusual event when the discharge canal radiation monitor alarme .0 Facility Management and Control 1

{ General The inspectors conducted frequent reviews of ongoing plant activities and attended licensee meetings and reviews addressing these activities, in order to assess overall facility management and controls. Specific events and findings are detailed in the sections belo .2 Oraanization. Manaaement. and Cost Controls at Permanently Shut Down Reactors (36801)

1. General The inspectors reviewed the licensee's systems for overall management and control of the decommissioning process. Specific processes which were selectively examined included the programs for identification and resolution of safety concerns and the commitment tracking programs and procedures. The inspectors also reviewed and evaluated the licensee's organization, staffing, qualifications and training, including those for the contracted workforce, to verify that licensing commitments were being me Reference was made to the requirements detailed in the Technical Specifications, the offsite dose calculation manual (ODCM), and the post-shutdown decommissioning activities report (PSDAR). The inspectors also t electively examined and evaluated the licensee's planning, scheduling and cost assessments to determine their effectivenes The effectiveness of the licensee's review of regulatory informs tion, including generic letters and information notices applicable to the facility, was selectively examine Specific events and findings are detailed in the section belo . Shift Crew Composition Chanaed Inspection Scope The inspectors reviewed TS 6.2.2, Table 6.2-1, " Minimum Shift Crew Composition for a Shutdown or Cold Shutdown Plant," and monitored the conduct of operation l l

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. Observations and Findinas On March 1,1998, the shift complement was changed from one shift supervisor, two control operators, and two auxiliary operators down to a shift complement of one shift supervisor, one control operator, and two auxiliary operators. A shift supervisor, one control room operator, and one auxiliary operator is required by TS 6.2.2, Table 6.2- The inspectors observed that when the control operator was out of the control room, the shift supervisor was present in the control room as require Five control operators have been removed from shift staffing. The operators' plant and licensing knowledge, years of experience, and skills are being utilized in the planning and training centers and work control cente Further reductions in shift complement have been proposed by the licensee which are under review by NR Conc!usion Changes in the shift complement reducing the shift crew composition by one control room operator anct one auxiliary operator were within the current TS requirements for a plant in cold shutdow . Radiation Protection (RP) Oraanizational Chanaes Inspection Scope The inspectors discussed with the site general manager and RP managers changes to the RP organization and the reasons for the change Observations and Findings The site general manager and RP managers recently included that one supervisor for 25 workers was not effectNe in supervision, communication, and control of the work group. On March 16,1998, the licensee reorganized the RP department and created the positions of RP supervisor containment, RP supervisor turbine side, RP supervisor counting room and instruments, and RP supervisor access control office. Each supervisor will now have about six people working for the Conclusion A lower RP supervisor-to-worker ratio should improve the effectiveness of the RP organization by increasing control and quality of RP activities performe . Decommissionina Expenditures The inspectors reviewed the requirements of 10 CFR 50.82 related to decommissioning costs, licensing budget reports, and cost performance trends and the licensee's 1997 and 1998 decommissioning expenditures. The monies spent on decommissioning activities were within the scheduler and expenditure requirements of 10 CFR 50.8 .3 Safety Reviews. Desian Chanaes. and Modifications at Permanentiv Shut Down Reactors (37801)

1.3.1 General The inspectors examined the licensee's safety review program to ascertain that the program was effective at identifying potential unreviewed safety questions (USO) in accordance with 10 CFR 50.59. The activities of the licensee's onsite and offsite safety review committees were evaluated to determine whether they were fulfilling their respective charters and the requirements of TS and the quality assurance (QA) plan. The training program for personnel performing safety evaluations was reviewed to verify that the qualifications of these personnel were adequate and were being maintaine Specific design changes or modifications were reviewed to assess program effectiveness in application including a review of written safety evaluations and other records. In addition, a sample of maintenance and repair activities was reviewed to ascertain whether the licensee had made changes to the facility without properly invoking their safety review process.

1.3.2 Procedures and Modifications Reviewed by Plant Safety Review Committee (PRC)

The inspectors determined that there were no USQs identified for the following procedures and modifications reviewed by the PRC:

e TV-60, " Fuel Pool Clearance and Flow Non-obstruction / Spent Fuel Pool Pipe Rail Verification" (new procedure) I e TV-39, "NULOM Hafnium / Hybrid Control Blade inspection" (canceled)

e Volume 1, Procedure D4.1.4, " Training Records" (new procedure - canceled Procedure 4.1.4, Revision 6)

e SOP-10, " Containment Vessel" (reviewed finished copy) )

e Volume 1 Procedure D1.0," Plant Decommissioning Organization and Responsibilities"

• SC-98-02, " Removal of Recirculation Pumps Seal Water Coolers"

• Volume 1, Administrative Procedure D3.1," Decommissioning Work Packages,"

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• Volume 1, Administrative Procedure D3.1.1.8, " Minor Alterations," Revision 1 e SOP-11, " Radioactive Waste System," Revision 134 (temporary change)

e Volume 3, ALP-1.4, " Station Service System Annunciator Window Layout," l Revision 163 (removal of No. 4 station air compressor) l l

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e Volume 1, Procedure D5.13, " Instructions of Worker's Responsibility Concerning l Radiological Conditions," Revision 0 l l

e Volume 1, Procedure DS.1, " Radiation Protection and Environmental Services Policy and Program Description,"(draft OA)

• Volume 3, SOP-27, " Service and Instrument Air System," Revision 123 (removal of No. 4 station air compressor)

e Volume 9, Site Emergency Plan Big Rock Point Plant, Appendix C, Revision 129 e Volume 1, Procedure D2.2.1," Performance of Maintenance and Decommissioning Work Activities," Revision 0

• Volume 9A, Big Rock Point Nuclear Plant Site Emergency Plan implementing Procedures, EPIP-4A, " Site Emergency Director," Revision 167 e Review of the Updated Final Hazard Summary Report 1.3.3 USQ Not Created by Security Plan for Permanently Defueled Plant The inspectors attended a PRC meeting where the security plan for a permanently defueled plant was compared to the existing security plan to determine that a USQ as ,

related to 10 CFR 50.59 did not exist. Certain combinations of spent fuel storage I configurations and decay times could cause freshly discarded fuel assemblies to self-heat I to a temperature where the self-sustained oxidation of zircaloy fuel cla f $ng co,uld cause cladding failure. Therefore, Consumers Energy Company will forward an analysis to the NRC with the determination of the point, after permanent shutdown, when the spent fuel decay heat is low enough such that no zircaloy oxidation takes place and the spent fuel cladding remains intact upon extended exposure to air. The security plan for a permanently defueled plant will not be implemented at Big Rock Point until the result of the zircaloy oxidation analysis for the SFP is received and evaluated by the licensee. If the result of the zircaloy oxidation analysis is negative, the security plan for a permanently defueled plan would not create a USQ. If the result of the zircaloy oxidation analysis is positive, the licensee will re-evaluate the proposed defueled security plan. The review of the security plan for a permanently defueled plant against the results of the zircaloy oxidation analysis is an Inspection Followup Item (50-155/98002-01(DNMS)). Decommissionina Performance and Status Review at Permanentiv Shut Down Reactors (71801)

1.4.1 General The status of decommissioning, and licensee and contracted workforce conduct of decommissioning activities in accordance with licensed requirements and commitments were evaluated. Control and conduct of facility decommissioning were examined to verify that license and TS requirements and commitments described in the Final Safety Analysis Report (FSAR, or equivalent), and PSDAR were being met and implemente Specific events and findings are detailed in the section belo I

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1.4.2 Annual Emeraency Preparedness Exercise for 1997 l

l l On March 31,1998, the annual emergency preparedness exercise for 1997 was conducted. Along with the licensee, the State of Michigan, Charlevoix County, and Emmet County participated in the exercise. Big Rock Point operated as a cell providing information to both the state and the counties. The Federal Emergency Management l Agency (FEMA) observed and evaluated the exercis The scenario was a fire in the radwaste building involving all the contaminated resin from the chemical decontamination of the primary system, which contained many curies. The burning resin caused hypothetically released activity to exceed the protection action guidelines for EPA-400, requiring the state and counties to perform the actions of a general emergenc The licensee informed the inspectors that all the objectives of the exercise were met and FEMA had no outstanding issues with any of the participants; therefore, the emergency exercise was successfully complete .4.3 Revised Updated Final Hazard Summary Report (UFHSR)

The licensee completed, approved, and implemented revisions to all chapters of the updated FHSR on March 13,1998, for the permanently defueled plan .4.4 Plant Tours to Evaluate Material Conditions _, Housekeeping. and Fire Protection a. Inspection Scope Plant tours were performed to evaluate the materialintegrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning, and to evaluate plant housekeeping and fire protectio b. Observations and Findinas l After conducting plant tours, the inspectors discussed the findings with plant management. The inspectors observed that plant management was actively monitoring plant housekeeping and fire protection. When issues arose, the issues were resolve One afternoon plant staff performed general cleanup activitie c. Conclusion The inspectors concluded that the materialintegrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained. Plant housekeeping and fire protection were generally good.

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. Onsite Followuo. Written Reports of Non-routine Events at Power Reactor Facilities 192700)

1.5.1 (Closed) VIO 50-155/97002-01: Failure to perform written safety evaluation to document that an unreviewed safety question did not exist. The inspectors reviewed the corrective actions for this violation which added additional reviews of technical changes and procedure revisions, including the associated 10 CFR 50.59 reviews. The inspectors also monitored numerous proposed procedure changes during PRC meetings. Based on the reviews, the inspectors concluded that the corrective actions were effective. This violation is close i 1.5.2 (Closed) VIO 50-155/97002-02: Failure to include a 1985 analysis in a 1989 FHSR change submittal. The licensee had not recognized the need to perform a 10 CFR 50.59 analysis and, therefore, did not recognize that a change was needed in the FHSR update submittal. The licensee now requires a safety evaluation and an updated FHSR submittal i for all revisions to plant procedures to be submitted to the PRC. This violation is close .5.3 (Open) VIO 50-155/97004-01: Two examples of failure to follow procedure in initiating and clearing equipment tagouts. The inspectors reviewed the corrective actions and verified that the'specified procedural changes had been made. However, the licensee has not accomplished many dismantlement activities to date. Major dismantlement activities are scheduled to start within the next few months. The inspectors will then determine if the corrective actions were effective. This item remains ope .5.4 (Closed) IFl 50-155/97006-01: Analyze plant protection strategy and incorporate into security department training. The inspectors reviewed the corrective actions and were satisfied that they were effective. This inspection followup item is close .5.5 (Closed) IFl 50-155/97006-03: Weakness in security procedures for physical barrier The inspectors reviewed the changes in the security procedures incorporated as a result of the noted weaknesses. The inspectors were satisfied that the changes were effectiv This inspection followup item is close l 1.5.6 (Closed) VIO 50-155/97011-01: Worker lying dowr* in a contaminated area. The l inspectors verified that the proposed management expectations had been issued and !

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discussed with all licensee radiation workers. The expectations were also incorporated into the general and contractor training. Based on interviews with licensee maintenance staff and observations of licensee activities, the inspectors concluded that the corrective actions were effective. This violation is close j 1.5.7 (Closed) VIO 50-155/97014-01: Radiation surveys not completed as required by TS This licensee identified violation involved an individual who failed to perform radiation surveys as required by station procedures. The licensee took appropriate disciplinary actions. The inspectors determined that the corrective actions were effective. This violation is close .5.8 (Closed) VIO 50-155/97014-02: Survey records required by 10 CFR 50.59 contained false information. This violation involved the same individual as detailed in Section 1. above. The individual had entered false information after failing to complete the radiation

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l surveys. The inspectors determined that the licensee's corrective actions were effective in preventing a reoccurrence. This violation is closed.

l 1.5.9 (Closed) VIO (50-155/97015-03): Worker failed to monitor electronic dosimetry every l 15 minutes when in a high radiation area. The inspectors determined that the corrective action for this violation was adequate to prevent reoccurrence. A sign was posted at the radiation work permit (RWP) control point instructing personnel to monitor their dosimetry every 15 minutes, and Health Physics (HP) technicians were instructed to help ensure that this was done. The event was discussed at all department meetings, and the worker

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This violation is close '

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l Decommissioning Support Activities ,

1 Maintenance and Surveillance at Permanently Shut Down Reactors (62801)

l l 2.1.1 General The inspection evaluated maintenance and surveillance for structures, systems, and !

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components (SSCs) potentially affecting the safe storage of spent fuel and reliable l operation of radiation monitoring and effluent control equipment. Direct observations, l reviews, and interviews of licensee personnel were conducted to assess whether i

! maintenance and surveillance were performed in accordance with regulatory requirements and resulted in the safe storage of spent fuel and reliable operation of radiation monitoring and effluent control equipment. This included the proper l implementation of TSs and 10 CFR 50, Appendix B, requirements. An examination of l planned or completed maintenance and surveillance activities was conducted to assess

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the maintenance and surveillance process from its inception to its completio '

I 2.1.2 Dirty Sump Containment isolation Valve Failed Valve Stroke Test l

! On March 20,1998, during performance of surveillance test T90-13, "ASME Boiler and l Pressure Vessel Code,Section XI, CV isolation," three attempts were made to close containment dirty sump outside isolation valve CV-4103. When the valve failed to close, an auxiliary operator (AO) tapped on solenoid valve SV-4896 for CV-4103 resulting in CV-4103 closing. On subsequent valve stroke tests CV-4103 operated satisfactorily. A work request was written to repair CV-4103 and the valve was declared inoperabl Containment integrity was maintained because containment dirty sump inside isolation valve CV-4025 operated satisfactorily. However, containment integrity is not required for a permanently defueled plant. The inspectors concluded that the above actions were adequat . Diesel Fire Pump Auto Start During performance of surveillance test T7-20, " Diesel Fire Pump Auto Start," after 5 minutes of the diesel fire pump engine running, the engine was 5 rpm above the normst speed band. The speed reading at engine shutdown was within the normal operating band. A work request had previously been written for maintenance to assess the engine speed control. The inspectors concluded that the tight speed controlis no longer

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required since the pump is not required as a core spray pump in a permanently defueled plan .1.4 Fuel Pool Heatup Te }t On March 27,1998, TV-59, " Fuel Pool Heatup Test," was completed. The heatup rate was 0.346 F/hr. The time for the SFP to heat from 80 F to 150 F is now 8.4 days which is greater than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assumed in the proposed defueled TSs. As the decay heat in the fuel decays away, there is more time for the licensee to respond to loss of cooling to the SF .2 Operational Safety Verification (71707)

2.2.1 General The inspectors conducted frequent reviews of ongoing decommissioning activitie Specific events and findings are detailed in the sections belo .2.2 Stack Gas Radiation Monitor Recorder inadvertentiv Shut Off Insoection Scope On March 12,1998, the duty on-call manager called the senior resident inspector (SRI) at home in response to the stack gas radiation monitor recorder inadvertently being shut-off requiring a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report to the NRC. The SRI investigated the circumstances related to this even Observations and Findinas On March 11,1998, at 10:13 p.m., Breaker Y-1 was opened to de-energize the containment high-range gamma monitor recorder in the control room, pursuant to tagging order No. 9840012. On March 12,1998, at 3:54 a.m., the oncoming control room operator (CO) discovered that the radio gas and effluent monitor (RGEM) unit noble gas high-range recorders were not operating. Investigation revealed that the recorders not ,

operating resulted from the opening of Breaker Y-1. At 4:45 a.m., Breaker Y-1 was closed and the RGEM unit retumed to service. The RGEM was inadvertently out of service for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 27 minutes before it was returned to servic Administrative Procedure 6.1," Reporting Requirements," requires that if emergency assessment capability is lost, a 1-hour telephone report to the NRC is required. The opening of Breaker Y-1 resulted in removal of the containment gamma monitors and the normal and high range noble gas monitors from service, effecting assessment capabilit The required report to the NRC was made on March 12,1998, at 6:21 The inspector's investigation determined that, prior to tagging, the shift supervisor (SS)

did not review the correct electrical drawing, which indicated that opening Breaker Y-1 would de-energize the RGEM equipment. Further, the SS did know that the radiation monitor control room alarm panel was already out of service. Because the alarms were out of service, compensatory measures were in place for the CO to check the radiation monitors once an hour and to log the readings. These actions were performed, but the

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CO did not notice that the power availaole lights were off. As the RGEM local unit was still operating, the radiation readings were normal, and the RGEM recorder pen was still indicating; however, the chart drive had stopped. Normally, the chart paper is dated at the beginning of each shift; however, on this occasion the CO had worked 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> over and the oncoming CO began his shift 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> early, and this wasn't done. Therefore, it was not noticed for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> by the on-duty CO that the RGEM was turned off and the two RGEM system control room monitors were de-energize Drawings reviewed by the inspectors were as follows:

e " Elementary Diagram Containment Gamma Radiation," Print No. 0740A30009, Sheet 029C, Revision 4 e " Elementary Diagram Radioactive Gaseous Effluent Monitoring," Print No. 0740G30762, Sheet 3, Revision 5 e " Connection Diagram," Print No. 0740G30709, Sheet 2, Revision U e "Panet Auxiliary Control Connection Diagram," Print No. 0740G30740, Sheet 3, Revision L e " Panel-Main Control," Print No. 0740G30741, Sheet 1, Revision D The inspectors concluded that the drawings were complex, but drawing No. 070G30762 clearly indicated that Breaker Y-1 provided 120 Vac power for the RGEM annunciatio Technical Specifications Table 13-3, " Radioactive Waste Sampling and Analysis Program," requires continuous sampling of the stack gas effluent. Technical Specifications Table 13-1, " Radioactive Effluent Monitoring Instrumentation," for the high range noble gas monitor has as an action statement "with the channelinoperable, initiate i

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the preplanned alternate method of monitoring the appropriate parameter, within 72-hours" and " restore the inoperable channel to operable status within 7 days." The RGEM unit was restored to operable status in 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 27 minutes; therefore, the ,

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limits of the action stat were not exceede In condition report (CR) C-BRP-98-051, Stack Gas instrument De-energized, the SS determined that one root cause was failure to completely verify that a tagging point did not affect other equipment. Another root cause was lack of awareness on the part of the control operator as to equipment status in the control roo The safety significance of this event was low. During an event, the RGEM unit would not have shifted to high range noble gas monitoring and the high range activity filters would i not have gone into service. The SFP area monitor was in service and, in the event of high radiation in the SFP, the monitor would have isolated containment vent valves terminating any radioactive release from the containment into the stack. The licensee's immediate corrective actions included requiring an engineer to technically review any electrical tagging points for any jumper-lifted lead or bypass activities require _

. Conclusion Inadequate review of electrical drawings for tagging of the opening of Breaker Y-1, followed by a CO's inattention to control board indications during hourly readings resulted in the RGEM equ!pment unknowingly being out of service for about 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> .0 Spent Fuel Safety General The inspectors evaluated the performance or condition of structures, systems or components associated with storage, control, and maintenance of spent fuel in a safe .

manne ) Spent Fuel Pool Safety at Permanently Shut Down Reactors Inspection Scope (60801)

The inspection evaluated spent fuel and fuel pool safety. Factors considered in the evaluation included SFP heatup rate; SFP instrumentation, alarms, and leakage detection; SFP chemistry and cleanliness control; criticality controls; and SFP operation and power supply, Observations and Findinas The inspectors reviewed AO logs containing SFP parameters and locally monitored SFP temperature, level and that no leakage was coming from the SFP liner telltails. The inspectors verified that the SFP area criticality monitor was functioning. The inspectors also observed that foreign materials controls were being used in and around the SF Conclusion i l

The inspectors concluded that the safety of the fuelin the SFP was being maintaine .3 Fuel Handlina Activities 3.3.1 Fuel Handlina Tool Caught on SFP Rack Inspection Scope (60710)

The inspectors reviewed logs, procedures, CRs, and inspection reports, and interviewed operators in the investigation of an operator snagging the fuel handling tool on the SFP rack. As fouowup actions, the inspectors reviewed changes to System Operating Procedure (SOP)-44 * Spent Fuel Pool Operations and New Fuel Handling," attended a pre-job briefing for weighing fuel bundles, and observed operators grappling and ungrappling fuel bundles when weighing the fuel bundle _ _ _ _ -

l b. Observations and Findinas On March 4,1998, a self-revealing event occurred when the fuel handing tool caught and then sprung-off the angle-iron of the SFP rack after an operator ungrappled from a fuel assembly. The operator was using the winch to take slack out of the winch cable, rather than to pull the slack out of the cable by hand, before the fuel handling tool was clear of the SFP rack. The operator stated that the fuel handling tool moved sideways, caught under the angle-iron, and then sprung loos Work was stopped, a CR and a daily order were written, and the load cell (scale) was I recalibrated. Previously tools had caught on the SFP rack (reference inspection report 50-155/97009(DRP), Section 01.2); therefore, it was decided to revise SOP-44 on March 5,1998. As corrective action, a caution at Step 6.2.2.f was added which states,

"Do not use the hoist to lift the cable until the grapple is free and clear of the component's handle, SFP racks and any other items in the spent fuel pool." Step 6.2.2.g was added which states, "When the grapple is free and clear of the component's handle, SFP racks and any other items in the Spent Fuel Pool, the hoist can be used to raise the grapple."

The winch has a 500-pound-pulling force and no electrical cut-outs. In accordance with Off-Normal Procedure (ONP)-2.105, " Fuel and Core Component Damage," the fuel handling tool, cables, winch, and the winch support beam were inspected for damage following the event. The shroud of the fuel handing tool and the load bearing pin in the fuel handling tool were found to be bent. The operators rebuilt the fuel handling tool with a new shroud and load bearing pin which were inspected prior to us After the event on March 8,1998, the inspectors attended a pre-job briefing for weighing fuel bundles. Past occurrences of tools catching on the SFP rack and the need to control tools and the slack in the winch cable until tools are above the SFP rack were discusse j The changes to SOP-44 were also discussed. On the same day, the inspectors observed l the use of the fuel handling toolin the weighing of fuel bundles. The inspectors observed that the operators controlled the fuel handling tool and controlled the slack in the winch cable as required by revised SOP-44. On March 20,1998, the licensee completed weighing fuel bundles. The fuel bundles were weighed to gather data to design the dry fuel casks. A total of 331 of 441 bundles were weighed and varied in weight from 390 pounds to 420 pound Past occurrences of tools catching on SFP racks include:

e On January 10,1997, CR C-BRP-97-0023 " Channel Grapple Bent" was writte An operator had been attempting to straighten-out and wind the winch cable correctly onto the winch. The channel grapple was lowered below the channel rack and caught on the lip of the channel rack. The operator had been watching the cable wind onto the winch, rather than watching the position of the channel grapple in the SFP. Corrective action was to trend CR C-BRP-97-0023. System Operating Procedure (SOP)-44, Revision 133, Step 3.0.a.1.B states, "The winch does not have a load cut-off switch, monitor load and winch for freedom of movement."

e On June 24,1997, CR C-BRP-97-0369 " Snagging Channel Grapple on Channel Rack" was written. While rewinding the cable onto the fuel pool winch, the

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channel grapple was lowered into a channel position hole. After straightening the cable, the channel grapple was being raised with the winch when the lower grapple guide bail caught the edge of the SFP rack. The operator had been d closely monitoring the cable winding onto the winch rather than the position of the channel grapple in the SFP. Corrective action was to review CR C-BRP-97-0369 during pre-job briefings prior to channel wor The safety significance of the March 4,1998 event was low. Minor damage occurred to l the fuel handling tool, which was not connected to the fuel bundle and did not touch a fuel I bundle when the event occurred; therefore, damage to a fuel bundle was not a concer I The licensee's immediate action taken appeared effective. Therefore, this example of failing to follow Procedure SOP-44 is considered a licensee-identified and corrected violation. This violaticn is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-155/98002-02(DNMS)). Conclusion A fuel handling tool caught on the SFP rack and sprung free after an operator failed to control the fuel handling tool and the slack in the winch cable, resulting in minor damage to the fuel handling tool. The revisions to the procedure should prevent recurrenc .3.2 Hiah Activity Sources Stored in the SFP 1 l Inspection Scope inspection Report 50-155/97015(DNMS) documented a concern that high activity sources stored in the SFP could be inadvertently pulled out of the SFP and expose individuals in ]

the area to very high exposure rates. To followup on the concern, the inspectors '

interviewed the manager of the radiation protection department and NPAD inspectors and reviewed documents pertaining to security for the sources stored in the SFP. The inspectors also toured the SF Observations and Findinas During the 50-155/97015(DNMS) inspection, the licensee issued a daily order to address the concern about access to the SFP sources. The order required that covers be placed over the SFP at all times and if the covers were removed to perform work in the SFP the covers must be replaced immediately after the work was completed. Prior to the end of the inspection, the licensee indicated that additional controls would be implemented to further control access to the cables holding the SFP sources. An Inspection Followup item (50-155/97015-02(DNMS)) was identified in the inspection report pending a review of the additional control Following the 50-155/97015(DNMS) inspection, the licensee implemented further controls by erecting physical barriers around the north, south, and east ends of the pool and posting the barriers with potential high dose rate warning signs. The refueling bridge, which was normally parked on the west end of the SFP, would serve as the remaining !

physical barrier. The licensee believed that these controls would be adequate to prevent inadvertent lifting of the stored sources from the poo I

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On February 2,1998, however, an NPAD inspector observed that the refueling bridge had been parked on the far east end of the pool, leaving only three of the physical barriers to prevent access to the SFP source cables in place. Even though the SFP was covered, the NPAD inspecto s concluded that the misplacement of the refueling bridge adversely affected the effectiveness of the SFP source cable controls. At the exit meeting, the licensee indicated that further controls would be considered and implemented. Pending review of the additional controls, the Inspection Followup Item (50-155/97015-02(DNMS))

will remain ope Conclusion Additional positive controls may be needed to control access to cables holding high activity sources in the SFP. Desian Control of Independent Spent Fuel Storaae Installation Components 3.4.1 Licensee's Self-Assessment of Transportable Storaae Canisters for Spent Fuel Inspection Scope (60851)

The inspectors assessed the licensee's self-assessment capabilities by reviewing the licensee's audit of the contractor for spent fuel canisters, Westinghouse Govemment Technical Services Division (GTSD) QA program. The QA program applied to safety related activities associated with engineering in support of the design of the transportable storage canisters for dry cask storage of spent fue Observations and Findinas The intent of the audit was to gauge the effectiveness of, and verify implementation of, the OA program for activities being performed in support of transportable storage canister design. The audit resulted in three findings: GTSD's lack of implementation and ,

oversight of the QA program; the failure to establish adequate design subcontractor l controls; and design verifications were less rigorous than those committed to by GTS j These findings will be addressed by GTSD in response to the audit. The GTSD audit j also identified other problems which were documented in deficiency reports by GTSD i during the audit and will be resolved by the GTSD corrective action progra Conclusion The licensee's self-assessment audit of GTSD's QA program identified fundamental weaknesses. The report provided GTSD management with elements to be changed to preclude problems that other cask storage venders have had with the design and fabrication of other spent fuel storage syste *

. Radiological Safety Occupational Radiation Exposure (83750)

4.1.1 General Numerous aspects of licensee processes to minimize occupational radiation exposure were selectively examined in order to evaluate overall radiation safety and to provide for early identification of potential problems. Areas examined included: audits and appraisals; planning and preparation; training and qualifications of personnel; external exposure control; intemal exposure control; control of radioactive materials and contamination; surveys and monitorings; and maintaining occupational exposure as-low- as-reasonably-achievable (ALARA). Specific events and findings are detailed in the sections belo .1.2 Annual Occupational Radiation Exposure Report Late On March 2,1998, the 1997 Annual Occurational Exposure Report was submitted one day late by the licensee. TS 6.9.1.4 states, "An annual report covering occupational exposure for the previous calendar year shall be submitted prior to March 1 of each year."

The late submission of the Annual Occupt.tional Exposure Report was administrative in nature and an isolated occurrence that was considered a minor violation by the inspectors. However, the late submission is a violation of TS 6.9.1.4. In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, NUREG-1600, Section 6.3.1.1, this is a Non-Cited Violation (50-155/98002-03(DNMS)).

The submitted 1997 Annual Occupational Exposure Report documented exposure sorted by work groups and job functions. The actual number of personnel 2100 mem. was 11 The inspectors had no concems with the repor .1.3 Radioloaical and Asbestos Cleanina of the Recirculation Pump Room Inspection Scope The inspectors attended meetings and briefings and evaluated ALARA practices related to the radiological and asbestos cleaning of the recirculation pump room. The inspectors also reviewed radiation work permit (RWP)-982030 and ALARA plannin Observations and Findinas On March 2,1998, radiological and asbestos workers started radiological and asbestos cleaning of the recirculation pump room. The process involved using a high-pressure-wash pump that sprayed water at pressures of up to 3,000 psig to eliminate all loose asbestos debris and reduce contamination levels in the roo The asbestos and radiation hazards involved in the cleaning required additional attention to safety. The inspectors attended a good task planning meeting; a management oversight and status meeting where the site manager stressed personnel safety versus scheduler pressure; a meeting to familiarize workers with area and radiation hazards, hot spots, and high dose components where the ALARA technician conducted an excellent

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presentation using a video of the steam drum area and recirculation pump room; and a good pre-job and ALARA briefing. Activities performed to reduce hazards were to plug all holes in the recirculation pump room to prevent the spread of asbestos and contamination; and use of portable high efficiency particulate activity (HEPA) filters to collect airborne asbestos and activity. Workers wore respirators until they were showered and debris was washed-off. Because the recirculation pump room is a high radiation area, ALARA practices included using teledosimetry and TV cameras to monitor the workers. Radiation protection personnel monitored and communicated with the workers through head sets worn by the workers. Workers were instructed to work in lower dose areas; thus, saving exposure. The washdown was also video-taped for use by other plant personne The washdown was started on March 3,1998, and was completed on March 12,199 Exposure to workers was 2.2 Person REM. HP personnel performed an evaluation and determined that the exposure received by workers performing the washdown was reduced by 90 percent because of the primary system chemical decontaminatio I Post-surveys of the steam drum area and recirculation pump room showed that the general area dose rate was reduced by a factor of 3.2 from 320 mR/hr down to 100 mR/hr, and the contamination levels were reduced by a factor of 10 from 400,000 dpm/100 cm2 to 400,000 dpm/100 cm2, Because of the high pressure washdown, less dose will be received by workers in the steam drum area when erecting scaffolding, abating insulation, removing recirculation pumps and motors and recirculation system pipin Conclusion The radiological and asbestos cleaning of the recirculation pump room was well planned and briefed. Health physics technicians and workers used excellent ALARA practices during the process. The washdown resulted in a large reduction in ganeral area dose rates and contamination levels.

4.1.4 Audit and Appraisals Inspection Scope (83750) (40B01)

l The inspectors reviewed approximately 30 NPAD Field Monitor Reports (FMR) written between November 1997 through the beginning of March 1998. The FMRs reviewed documented the findings of assessments conducted by the NPAD on the radiation protection program. The inspectors also interviewed the NPAD inspector responsible for overseeing the RP progra Observations and Findings in general, the NPAD assessments as reported in the FMRs were very good. The NPAD inspectors responsible for overseeing the radiation protection program has an extensive background in health physics, appeared to be knowledgeable about Big Rock Point's radiation protection program, and as evidenced by the findings in

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l the FMRs, was very conscientious about identifying deficiencies in the radiation protection progra However, documentation detailing NPAD's followup of deficiencies identified in the FMRs appeared to be lacking. For example, in nine of the 30 FMRs reviewed the

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inspectors documented finding radioactive materials and/or containers that housed l radioactive materials that were not properly labeled as required by station l Procedure RPG-18 " Radiological Labeling." In several of the FMRs, the inspectors l noted that failing to label was a repeat finding as noted in previous FMRs. In only one case did NPAD initiate a CR to address the finding. Other reoccurring deficiencies, including inadequate radiological postings and poor worker practices, l were also reported in the reviewed FMRs. Few, if any of those, were addressed in l l a CR.

I i During the interview, the NPAD inspector indicated that NPAD findings are

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routinely discussed with plant management and progress in correcting deficiencies documented in the reports is monitored. In most cases, however, the followup

, actions were not documented. NPAD also issues monthly summaries of findings l which address negative as well as positive findings and are sent to plant management. NPAD does not, however, document the summary assessments of management's effectiveness in correcting the negative findings.

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During the exit meeting, the director of NPAD acknowledged that NPAD inspectors may have been deficient in not initiating CRs to address significant findings. The director indicated that NPAD had initiated a draft CR to determine if NPAD inspectors has been in compliance with NPAD Procedure NPAD-07, " Guidance on Initiating Condition Reports," and Administrative Procedure 1.3," Condition Report Initiation Guidance." NPAD-07 directs NPAD staff members to initiate a CR if l findings meet the criteria in Administrative Procedure 1.3. NPAD concluded in l the draft CR that CRs should have been initiated to address findings in five of the 30 FMRs reviewe Since CRs require documented followup, this CR appeared to have addressed the l concerns raised by the NRC inspectors conceming documentation of significant l

findings and documentation of actions taken to correct deficiencies.

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Documentation of NPAD followup of findings regarding labeling of radioactive materials and/or containers housing radioactive materials and poor radiological l safety practices by workers appeared to be weak. Initiation of a CR to address this l weakness appeared to be a good first step in resolving the issue.

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. Radioactive Waste Treatment, and Effluent and Environmental Monitorina 4. Radioloaical Environmental Monitorina Proaram Inspection Scope (84750) (80721)

l l The inspectors reviewed the circumstances surrounding an incident in which a j radiation effluent detector monitoring the discharge canal spiked and alarmed hign.

l The inspectors reviewed Event Report-33901 initiated to address the incident, l operator logs generated during the event, and interviewed individuals responsible j for the effluent monitoring program.

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I Observations and Findinas On March 14,1998, a radiation effluent detector monitoring the discharge canal l spiked and alarmed high on several occasions. Subsequently, the same detector i

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spiked high several times on March 15,1998, and March 25,1998. Following the March 14 incident, the facility declared an " Unusual Event" and initiated an event report, j During the inspection, the licensee indicated that the investigation of the incidents l would not be completed before the end of the inspection period. Preliminary

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results of the investigation ind;cated that the elevated discharge canal monitor

! readings were not the results of radioactivity in discharges from the plant but were l from either contaminated Algae or sediment that had been concentrated in the canal by high wind ,

Pending review of the licensee's investigation, this is identified as an Inspection Followup Item (50-155/98002-04(DNMS)). . Conclusion No condusions can be drawn from the incidents until the licensee's final investigation report is reviewe .3 Solid Radioactive Waste Manaaement and Transportation of Radioactive Materials 4.3.1 Shippina of Low Level Radioactive Waste for Disposal Inspection Scope (86750)

The inspectors reviewed the circumstances surrounding an incident in which hazardous waste (mercury) wat inadvertently shipped to a waste processing facility. The inspectors reviewee CR C-BRP-98-038 initiated to address the incident and interviewed individus.8,i responsible for the shipping of radioactive material . Observations and Findinas On February 24,1998, a worker at the GTS/Duratek waste processing facility in Oak Ridge, Tennessee, discovered metallic mercury leaking from a bag of waste that had been shipped from Big Rock Point. The bag was one of many bags that had been packaged in a B-25 box at BRP on September 18,1997. During unloading of the B-25 box, the worker noticed that about 4 ounces of mercury had leaked from a yellow bag onto the processing floor. The bag was opened and a broken manometer was found inside. The Big Rock Point RP department was notified immediately and the RP manager was sent to the facilit Because mercury was a hazardous waste prohibited by GTSD's waste acceptance criteria, the spill was immediately remediated. The mercury, the waste generated, )

and the broken manometer were immediately retumed to BRP. A CR, C-BRP-98-038, was initiated to address the incident and all radioactive shipments were suspended pending the results of an investigatio The preliminary investigation concluded that the root cause of the incident was that the bagged manometer had been temporarily stored in a B-25 box and the box had been shipped without a check of the contents. If the contents of the B-25 box had l been checked, someone should have noticed that the bag was marked "Do Not l Ship." Contributors to the incident included storing hazardous waste, as well as l non-radioactive waste, in the radwaste building; not having a designated l hazardous waste storage area; and not utilizing the waste manifest process i properl )

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Proposed corrective actions included segregation of hazardous waste from Other waste and enhancing the waste segregation and manifesting process. At the exit meeting, plant management indicated that further corrective actions were under

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consideration. Pending review of those corrective actions this is identified as an Inspection Followup Item (50-155/98002-05(DNMS)). Conclusion The mercury incident at GTSD demonstrated significant weaknesses in the licensee's radioactive and hazardous waste shipping progra .0 Exit Meeting Summary The inspectors presented the inspection results to members of licensec management at the conclusion of the inspection on April 6,1998. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietar l

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I PARTIAL LIST OF PERSONS CONTACTED Licensee i

K. Powers, General Manager D. Hice, Plant Manager G. Szczotka, Manager Nuclear Performance Assessment Department 4 K. Pallagi, Radiation Protection and Environmental Manager j W. Trubilowicz, Scheduling and Project Control Manager j G. Withrow, Engineering Manager 1 D. Debner, Nuclear Fuel Projects Manager C. Jurgens, Construction Manager K. Wooster, Emergency Planning Manager M. VanAlst, Security Manager L. Potter, Maintenance Supervisor L. Darrah, Operations Supervisor G. Hausler, Work Control Supervisor D. LaCroix, Training Supervisor G. Rowell, Corrective Action Supervisor M. Bourassa, Licensing Supervisor G. Petitjean, Senior Engineer (Alternate PRC Chairman)

E. Zienert, Human Resources Director T. Mosley, Senior Engineer Reactor Protection Projects J. Corley, Nuclear Performance Assessment L. Berry, Site Licensing Engineer K. Shields, Nuclear Fuel Project Reactor Engineer INSPECTION PROCEDURES USED IP 36801: Organization, Management, and Cost Controls at Permanently Shut Down I Reactors IP 37801: Safety Review, resign Changes, and Modifications at Permanently Shut Down Reactors IP 40801: Self-Assessment, Auditing, Corrective Action IP 60710: Fuel Handling Activities l lP 60801: Spent Fuel Pool Safety at Permanently Shut Down Reactm l IP 60851: Design and Control of ISFSI Components IP 62801: Maintenance and Surveillance at Permanently Shut Down Reactors IP 71707: Operational Safety Verification IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down Reactors IP 80721: Radiological Environmental Monitoring IP 83750: Occupational Radiation Exposure IP 84759: RadWaste Treatment, Effluent and Environmental Monitoring IP 86750: Solid RadWaste Management and Transportation of Radioactive Materials IP 92700: Onsite Followup, Written Reports or Non-routine Events at Power Reactor Facilities

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ITEMS OPENED AND CLOSED t

OJened 50-155/98002-01 IFl Review of zircaloy oxidation analysis 50-155/98002-02 NCV Failure to follow procedura when fuel handling tool caught on SFP rack 50-155/98002-03 NCV Annual Occupational Radiation Exposure Report late 50-155/98002-04 IFl Algae containing Cobalt 60 in discharge canal

, 50-155/98002-05 IFl Hazardous waste in radioactive shipment Closed 50-155/97002-01 VIO Failure to perform written safety evaluation to document that an unreviewed safety question did not exist 50-155/97002-02 VIO Failure to include 1985 analysis in 1989 FHSR change submittal 50-155/97006-01 IFl Analyze plant protection strategy and incorporate into security department training 50-155/97006-03 IFl Weakness in security procedures for physical barriers

50-155/97011-01 VIO Worker lying down in a contaminated area 50-155/97014-01 VIO Radiation surveys not completed as required by TS 50-155/97014-02 VIO Survey records required by 10 CFR 50.59 contained false J information '

50-155/97015-03 VIO Worker failed to monitor dosimetry while in a HRA 50-155/98002-02 NCV Failure to follow procedure when fuel handling tool caught on SFP rack 50-155/98002-03 NCV Annual Occupational Radiation Exposure Report late Reviewed and Remain Open 50-155/97004-01 VIO Two examples of failure to follow procedure in initiating and clearing equipment tagouts 50-155/97015-02 IFl Licensee's resolution for positive control over cables hanging in the SFP

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LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable ALP Alarm Procedures AO Auxiliary Operator ASME American Society of Mechanical Engineers CFR Code of Federal Regulations CO Control Operator CR Condition Report CV Control Valve DNMS Division of Nuclear Materials Safety dpm Disintegrations per minute DRP Division of Reactor Projects EPA Environmental Protection Agency EPIP Emergency Preparedness implementation FEMA Federal Emergency Management Agency FHSR Final Hazards Summary Report FMR Field Monitor Reports FSAR Final Safety Analysis Report GTSD Govemment Technical Services Division HEPA High Efficiency Particulate Activity HP Health Physics IR Inspection Report ISFSI Independent Spent Fuel Storage Installation LTP License Termination Plan NRC Nuclear Regulatory Commission NPAD Nuclear Performance Assessment Department ODCM Offsite Dose Calculation Manual PRC Plant Safety Review Committee PSDAR Post-Shutdown Decommis',ioning Activities Report PSIG Pounds per Square Inch Gauge QA Quality Assurance RadWaste Radioactive Waste RGEM Radio Gas and Effluent Monitor RP Radiation Protection RWP Radiation Work Permit l SFP Spent Fuel Pool SOP System Operating Procedure SRI Senior Resident inspector l SS Shift Supervisor j SSCs Structures, Systems, and Components l TS Technical Specification l TV Test Variable USO Unreviewed Safety Questions

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