IR 05000155/1978003
| ML20002E413 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/04/1978 |
| From: | Essig T, Greer R, Januska A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20002E412 | List: |
| References | |
| 50-155-78-03, 50-155-78-3, NUDOCS 8101270883 | |
| Download: ML20002E413 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Report No. 50-155/78-03 Docket No. 50-155 License No. DPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility name: Big Rock Point Nuclear Plant Inspection at:
Big Rock Point Site, Charlevoix, MI Inspection conductod: March 7-10, 1978 h.
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Inspectors:
A. G.
anuska 3/ 78 (.b. kh
R.3.Greer If f 3 %
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Approved by:
T. H. Essig, nief b
E Environmental and Special Projects Section Inspection Summary
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Inspection on March 7-10, 1978 (Report No. 50-155/78 'J3)
Areas Inspected: Reviewed emergency planning relatiag to agreements and coordination with offsite agencies; facilitier, equipment and procedures; records of tests, drills, and training; reviewed environ-mental monitoring program rcsults; discussed confirmatory measurement results from a previous sample collection, and reviewed records and procedures pertaining to radioanalytical laboratory quality control programs. The inspection involved 52 inspector-hours onsite by two NRC inspectors.
Results: No items of noncompliance or deviations were identified.
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I DETAILS
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1.
Persons Contacted,
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Principal Licensee Employees
- C. Axtell, Plant Health Physicist (BRP)
- T. Brun, Chemistry and Radiation Protection Supervisor (BRP)
- G. Gilbody, Quality Assurance (BRP)
T. Fisher, Quality Assurance Auditor (BRP)
- J. Flynn, Operations Supervisor (BRP)
M. Dickson, Senior Engineering Technician (CP)
- H. Jury, Radiological Training and Coordination Supervisor (CP)
B. Skibitsky, Senior Licensing Engitteer (CP)
R. English, Consumers Power Offsite Agencies I. Seidel, R.N., In-Service Director, Charlevoix Hospital G. Lasater, Sherif f, Charlevoix County J. Curtis, Chief, Charlevoix Fire Depsrtment C. Smith, R.N., Emergency Room Supervisor, Northern Michigan Hospital, Inc., Little Traverse Division N. Croff, sib 31ance Driver, Petosky Fire Department M. Wiklanski, Ambulance Driver, Petosky Fire Department
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2.
Licensee Action on Previous Inspection Findings (Closed) Outstanding Inspection Item (50-155/77-04): Completion of a study to determine radiation shine dose from the contain-ment sphere and containment penetratir,n leakage. The licensee has completed this study, and submitted it to the NRC on August 29, 1977, with a revision submitted February 2, 1978. The inspectors reviewed these studies, discussed them with site and corporate personnel, and determined them to be adequate.
(Closed) Outstanding Inspection Item (50-155/77-04):
Incorporation of State of Michigan or EPA Protective Action Guides (PAG's)
into the Site Emergency Plan. State of Michigan PAG's were incorporated into the Plan in a December 1977 revision. The State PAG's are more restrictiva than the EPA PAG's.
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General
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This inspection consisted of an examination of the licensee's
environmental monitoring and emergency planning programs, a
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discussion of the licensee's analyses of actual effluent samples, and a review of the licensee's program for quality assurance of analytical measurements.
The emergency planning portion of the inspection included an examination of the Big Rock Point Plant Site Emergency Plan (Revision No. 40, January 10, 1978) and implementing cards.
Principal offsite support agencies were visited, documentation pertaining to various aspects of the emergency plan was reviewed, and selected emergency equipment was inspected.
The licensee's radiological environmental activities, monitoring results, and management control were examined. The licensee conducts a radiological monitoring program, although the Technical Specifications require only film monitorinE+
Confirmatory measurement results of effluent samples were compared to those of the NRC reference laboratory, and discussed with the licensee. The measurements made by the NRC reference (
laboratory are referenced to the National Bureau of Standards.
The licensee's program for quality assurance of laboratory analytical measurements was also discussed.
4.
Emergene,y Planning a.
Coordination with Offsite Agencies The inspectors visited the Charlevoix Hospitel; Northern Michigan Hospital, Inc., Little Traverse Division; Charlevoix Fire Department; Charlevoix County Sheriff; and the Petosky Fire Department to determine if coordination between the agencies and the licensee is being maintained. Representa-tives of the first four agencies listed stated that coordina-tion and training provided by the licensee is adequate.
However, two ambulance drivers from the Petosky Fire Department stated that they had not been trained, although at least one of them had participated in an Emergency Plan drill conducted in 1977. The licensee stated that although Petosky Fire Department ambulance drivers had been given formal training in the past, retraining would be provided during 1978. This item will be reviewed during a future i
inspection.
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i While reviewing letters of agreement from offsite support
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agencies, the inspectors noted that at least two of the letters had not been signed by the current agency head.
The Charlevoix County Sheriff stated that he would prefer
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to sign a letter himself. This was discussed with the licensee, who stated that new letters of agreement would be sent to the Charlevoix County Sheriff and the Petosky Fire Department. The letters of agreement have a clause extending the term of the agreement from year-to year from the date of issuance unless terminated as provided therein, thus eliminating the need for annual updating of the letters.
b.
Facilities, Equipment, and Procedures The inspectors reviewed emergency kit inventory sheets for 1977 and found that the kits had been inspected on the required frequency, and that the contents were as required.
The portable air sampler to be taken on the ambulance was found to be inoperable; however, the licensee submitted it for repair prior to termination of the inspection.
Emergency supplies at both hospitals were examined. The inspectors noted that inventory sheets were apparently not available for either locker. This was discussed with the
licensee, who agreed to check the lockers and supply an inventory sheet if necessary.
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Emergency Plan implementing cards were reviewed. Some cards were found to need revision. The Plant Health Physicist was beginning the required quarterly review of the cards, and stated that these cards would be changed.
Records showed that the Plan was reviewed as required in 1977. This item will be reviewed in a future inspection.
c.
Tests, Drills, and Training The inspectors reviewed documentation of tests and drills conducted during 1977, and determined that requirements in Section 9.11 of the Site Emergency Plan had been met.
However, it was noted that documentation of follow-up action on areas needing improvement was missing. The licensee stated ti.at, in the future, documentation of follow-up action would be provided.
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The inspectors reviewed training records for site personnel and certain offsite agencies and determined that the requirements in Section 9.12 of the Site Emergency Plan
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had been met.
No items of noncompliance or deviations were identified.
5.
Environmental Monitoring The licensee's environmental monitoring program and gyntractural services have not changed since the last inspection.-
a.
Air Samplers Three air sampling stations, chosen at random, were visited and found to be operationg).
In response to an item discussed in a previous inspection,-- the licensee has oriented the charcoal filters horizontally.
b.
Film Monitoring Monitoring results for 1977 were examined. Apparent errors of dates of exposure were resolved with a General Office representative. No unusual results or trends were observed.
c.
Voluntary Radiological Honitoring Program The licensee presently conducts a radiological monitoring program not required by the Technical Specifications. The inspectors examined data generated by this program through September, 1977. The licensee is presently conducting an evaluation of the use of thermoluminescent dosimeters (TLD's)
In addition to the required film monitoring, the licensee samples milk, lake water, well water, algae, fish, and periphyton.
No anomolous results or trends were noted.
6.
Audits The inspectors reviewed records of audits conducted in 1977 by both plant and General Office personnel.
These audits included various aspects of the EmerEency Plan, environmental program, and laboratory radiochemistry. No major problems or deficiencies in the program were noted.
If IE Inspection Rpt No. 50-155/74-04.
2/ Ibid.
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7.
Results of Comparative Analyses
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Results of comparative analyses performed on effluent samples split at the site in November of 1977 are shown on Table 1.
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criteria for comparing measurement results are given in Attach-
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m_at 1.
For twenty two sample comparisons, the licensee's results yielded eighteen agreements or possible agreements. The results were discussed with the licentee. The licensee failed to identify Cr-51 on his particulate filter and Hg-203 on his charcoal adsorber.
An examination of the licensee's analyses did not indicate the presence of either nuclide on his computer printout and no reason for the failure to identify these nuclides was apparent.
The licensee failed to accurately guantify Mn-54 on his par 6.cu-late filter and Co-60 on his charcoal adsorber.
Investigation failed to identify a reason.
The inspectors noted that the licensee's resulta for the particu-late filter except for Cr-51, were higher than HSL's results and that none are in the agreement category. The inspectors and the licensee representatives discussed the possibility of an improper calibration, or damage to the calibration standard used. The licensee representative acknowledged the inspectore' comments and stated that this geometry had been calib:sted in December of 1977, using a standard made from a newly acquired standard solution.
This will be examined during a future inspection.
8.
Licensee Program for Quality Control of Analytical Measurements The inspectors discussed the assignment of responsibility and authority for management control of analytical measurements and reviewed all procedures associated with radiological measurements of effluents and nonradiological measurements of reactor coolant water quality.
A review of records for counting equipment backgrounds and calibrations revealed that the proportional counter is checked daily, a plateau established weekly and a calibration performed annually or after major repair or maintenance. The TASC-2 (GeLi)
system is energy calibrated weekly. Efficiency verficiation counts must be within a prescribed range. The RIDL (Nal) system uses the same checks as the TASC-2 system.
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Procedure numbers RCP-2 (Revision 3), RCP-9 (Revision 1),
RCP -22, CIP-10 CIP-11. CIP-13, CAP-5, and CAP-7 were reviewed.
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All procedures were issued December 31, 1976, and have a two year review requirement.
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9.
Exit Interview TF inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of this inspection on March 10, 1978. The purpose, scope, and findings of the inspection were discussed. The licensee agreed to:
Send new letters of agreement to the Charlevoix County a.
Cheriff and the Petosky Fire Department; b.
Provide documentation of follow-up action for items identified in tests and drills; Provide adJitional training for ambulance personnel c.
in the Petosky Fire Department; d.
Provide inventory sheets for the emergency lockers in the two hospitals listed in Paragraph 1; and Update the Emergeticy Plan implementing cards.
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Attachments:
1. Table 1, Confirmatory Measurements Program 2. Attachment 1, Criteria for Comparing Analytical Measurements
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ATTACittrirr 1
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CRITERIA FOR C_0SIPARTMC A_ nap _TICAL 11DSllRDirNT,5 j
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This attachment provides criteria for comparing results of capability
tests and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy
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needs of this program.
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In these criteria, the judgment limits are variable in relation to the
comparison of the NRC Reference Laboratory's value to its associated
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one sigma uncertainty. As that ratio, referred to in this program as
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." Resolution", increases, the acceptability of a licensco's measurement
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should be more selective. Conversely, poorer agreement should be con-sidered acceptabic as the resolution decreases.
The values in the ratio criteria may be rounded to fewer significant figures to maintain statistical consistency with the number of significant figures reported
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by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptance. The acceptance categcry reported will
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be the narrowest into which the ratio fits for the resolution being used.
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kATIO = LICENSEE VALUC/URC REFERENCE VALUE
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RESOLUTION
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Possible Possible
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Agreement greement "A" greeabic "B"
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<3 No Comparison No Comparison No Comparison
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>3 and <4 6.4 3.0 No Comparison
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2.5 0. 3
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3.0 2.5 0.3 2.0 0.4 T4 and <8 0.5
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2.0 0.4 2.5 1.67 0.5 O.6
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78 and <16
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2.0 1.67 0.5
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li16 and <51 0.75 - 1.33 0.6
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1.67 1.33 0.6 3I51 and <200 0.80 1.25 0.75
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1.33
.][200 0.85 - 1.18 0.80 -, 1.25 0.75
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"A" criteria are applied to the following analyses:
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Camma spectrometry, where principal gamma energy used for identifi-
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cation is greater than 250 kev.
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Tritium analyses of liquid sampics.
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"B" criteria are applied to the following analyses:
Camma spectrometry, where principal gamma energy used for identifi-
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, cation is less than 250 kcV.
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Sr,-89 and Sr-90 determinations.
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Cross beta, where samples are counted on the same date using the
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. same reference nuclide.
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TABLE I U S NUCLEAR RE GUL ATOR Y COMMISSION OFFICE OF INSPE C TION A ND E NF O R C E M E N T CONFIRMATORY MF ASUREMENTS PROGR A M FACILITY: BIG ROCK PT FOR THE 4 QUARTER OF 1977
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SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T
OFF GAS XE 133 4 0E-03 1 2E-04 4 5E-03 3 6E-04 1 1E+00 3 3E +01 A
XE 133M 5 5E-04 7 0E-05 7 0E-04 6 0E-06 1 3E+00 7.9E+00 A
L WA STE BETA 3 1E-04 1 0E-0 5" 3 1E'-04 1 2 E -0 5 1 0E+00 3 1 E + 01 A
H 3 2 7E -0 3 2 0E-05 3 2E-03 3 0E-04 1 2E+00 1 3E +02 A
SR 89 3 0E-07 2 0E-07 2 2E-06 3.0E-07 7 3E+00 1 5E+00 N
SR 90 3 5E-06 2 0E-07 2 2 E -0 6 2 0E-07 6 3E-01 1 8E+01 P
CS 1 34 3 8E-05 1 2E-0 6 4 0E-05 7 0E-07 1 1E+00 3 2E +01 A
CS 137 2 3E-04 6 7E-06 2 2E-04 1 0E-06 9 6E-01 3 4E+01 A
MN 54 6 1E-05 1 9E-06 7 6E-05 1 0E-06 1 2E+00 3 2E +01 A
FF 59 6 3E-06 1 2E-06 8 7E-06 1 1E-06 1 4E+00 5 2E+00 A
ZN 65 3 2E-05 1 5E-0 6 2 7E-05 1.7E-06 8 4 E -01 2 1E+01 A
CO 60 1 5E-04 4 5E-06 1 8E-04 1 0E-06 1 2E+00 3 3E+01 A
P FIL1ER CF 51 5 7E-04 1 1E-04
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5 2E+00
BA 140 2 6E-03 1 5 E -0 4 3 8E-0 3 2 0E-04 1 5E+00 1 7E +01 P
CS 1 34 3 7E-04 1 7E-05 6 0 E -0 4 4 7E-0 5 1 6E+00 2 2E +01 P
CS 137 1 3E-03 4 5E-05 2 0E-03 8 0E-05 1 5E+00 2 9E +01 P
MN 54 2 3E-94 1 4E-05 5 1E-04 4 9E-05 2 2E+00 1 6E +01 D
CD 60 5 1F-04 2 5E-05 6 8E-04 1 0E-04 1 3E+00 2 0E+01 P
I 131 1 9L-04 5 0E-05 4.BE-04 4 3E-05 2 5E+00 3 8E+00 P
ZU 65 1 7E-04 2 0E-05 2 9F-04 9 3E-05 1 7E+00 8 5E +00 P
C FIL1EF I 1 31 4 4E-03 1 8E-04 3 8E-03 8 0E-05 c.6 E -01 2 4E +01 A
CO 60 5 5E >#5 1 5E-05 7 5E-04 5 6E-05 1 4E+01 3 7E +00
HG 203 4 8E J5 1 1E-05
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i TES1 EESULTS A = A Gl.E E ME N T D=0I S A CREE ME N T PnPOSSIBLE AGREEMENT NaND COMPAPISON (
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