ML20126K354
| ML20126K354 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/12/1985 |
| From: | Greger L, Nicholson N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20126K338 | List: |
| References | |
| 50-155-85-08, 50-155-85-8, IEB-84-03, IEB-84-3, NUDOCS 8506190231 | |
| Download: ML20126K354 (8) | |
See also: IR 05000155/1985008
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-155/85006(DRSS)
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 Conducted: May 13-17, 1985
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Inspector:
N. A. Nicholson
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Date
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Approved By:
L. R. Greger, Chief
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Facilities Radiation Protection
Date
Section
Inspection Summary
Inspection on May 13-17, 1985 (Report No. 50-155/85008(DRSS))
Areas Inspected:
Routine, unannounced inspection of the radiation protection
and radwaste programs including:
control of radioactive material ;
transportation; solid radwaste; facilities and equipment; staffing; licensee
inspection of the recirculation pump seals; licensee response to IE Bulletin 84-03; and selected open items.
The inspection involved 38 inspector-hours
onsite by one NRC inspector.
Results:
No apparent violations were identified.
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DETAILS
1.
Persons Contacted
- R. Alexander, Technical Engineer
- J. 8eer, Chemistry / Radiation Protection (C/RP) Superintendent
- R. Burdette, C/RP Supervisor
G. Fox, C/RP Supervisor
- R. Frisch, Senior Licensing Analyst
R. Garrett, C/RP Supervisor
- T. Hancock, C/RP Engineer
- D. Hoffman, Plant Superintendent
- L. Monshor, Quality Assurance Superintendent
- G. Slade, Executive Director, NAD
D. VanDeWalle, Director Nuclear Licensing
- J. Werner, C/RP Supervisor
- S. Guthrie, Senior Resident Inspector
The inspector also contacted C/RP technicians and members of the
engineering staff during this inspection.
- Attended the May 17, 1985 exit meeting.
2.
General
This inspection, which began at 1:30 p.m. May 13, 1985, was conducted to
review the operational radiation protection program including control of
radioactive material, transportation, solid radwaste, C/RP staffing,
protective measures taken during entry into the recirculation pump area,
disposition of contaminated soil, the status of the facial hair / respirator
use policy, and response to IE Notice 84-03 (Refueling Cavity Water Seals).
Area postings, access controls, and housekeeping were good.
3.
Licensee Action on Previous Findings
(0 pen) Open Item (155/84-08-01):
Licensee representatives have not
contacted NRR regarding disposal of the onsite contaminated soil pursuant
to 10 CFR 20.302.
Although the licensee was informed of the need for
such contact during inspections conducted in July 1984 and and September
1984, the licensee concluded that formal notification of NRR was not
necessary.
This position was stated in a December 6, 1984 letter to
Region III.
Region III referred this matter to the Radiological
Assessment Branch of NRR for guidance in a March 14, 1985 memo.
The NRR
response, dated April 11, 1985 (Attachment 1), concluded:
(1) the
contaminated soil must be properly disposed either by excavation and
offsite shipment, or by inplace disposal pursuant to 10 CFR 20.302
approval; and (2) the licensee must account for concentrations released
to unrestricted areas as they occur in accordance with 10 CFR 20.105 and
20.106.
This matter was discussed at the exit meeting.
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(0 pen) Open Item (155/84-12-01):
Replace Bio-Pak 60P respirators with
open circuit SCBAs.
The licensee has procured the SCBAs and has ordered
a cascade _ system for refilling SCBA tanks.
Licensee representatives
anticipate the SCBAs to be in service by July 1, 1985.
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(0 pen) Open Item (155/84-22-01) and Unresolved Item (155/84-22-01):
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Administrative procedure allows persons with facial hair, including
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members of the fire brigade and radiation protection technicians, to wear
SCBAs during emergencies.
By a March 14, 1985 cover letter to the
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licensee, Region III forwarded an IE memorandum concerning facial hair
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prohibitions.with tight fitting respirator use.
Currently the
respirator / facial hair policy is under review by licensee management.
Licensee representatives committed to contact Region III by mid-June
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regarding the conclusions of that review.
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(0 pen) Deviation (155/85003-02):
Feilure to implement Sections X and XI
of the Nuclear Operations Department Radiation Safety Plan by March 1983.
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The Radiation Safety Plan is being revised and will be implemented
September 30, 1985.
This will be reviewed during a future inspection.
(0 pen) Open Item (155/85003-01):
Minimal QA coverage of health physics
activities.
The inspector reviewed a recently issued QA audit report
(QT-85-4) of health physics activities, including the transportation
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program.
The health physics department had not responded to the
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findings.
This item will be further reviewed.
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4.
Control of Radioactive Materials and Contamination
The inspector reviewed the licensee's program for control of radioactive
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materials and contamination, including:
adequacy of supply, maintenance,
and calibration of contamination survey and monitoring equipment; effec-
tiveness of survey methods, practices, equipment, and procedures; adequacy
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of review and dissemination of survey data; and effectiveness of methods
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of control of radioactive and contaminated materials.
2 is used for decontamina-
In general, a threshold level of 400 dpm/100 cm
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tion.
Contaminated areas greater than 400 dpm/100 cm2 that cannot be
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readily decontaminated because of ALARA considerations are positively
controlled by physical boundaries.
Although the extent of contaminated
areas is not tracked, the C/RP Superintendent estimated approximately 10%
of the controlled area is boundaried.
Survey data reviewed indicated
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general area smears of the controlled area below the 400 dpm/100 cm
The highest smearable contamination was consistently found at the reactor
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deck, a boundaried area.
The licensee has established a routine decontamination program.
General
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areas of the sphere are deconned monthly.
Under a recent policy
implemented in late 1984, higher contaminated areas are identified and
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scheduled for decontamination.
Four decontamination lockers have recently
been positioned throughout the plant to increase availability of supplies.
Management is reviewing this policy to determine its effectivenss.
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Maintenance and/or operations personnel may decontaminate a contaminated
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area resulting from a specific maintenance or operations function;
however, radiation protection and chemistry personnel complete most
decontamination work.
There are no dedicated decontamination workers.
The inspector accompanied an RP/C technician on a routine daily survey in
accordance with RP-29, Radiological Surveys.
Instruments in use and those
stationed throughout the plant were operable and calibrated.
No problems
were noted.
Personnel contamination reports were reviewed.
Reports are routinely
tracked as an ALARA measure and sources /causes of the contamination are
reviewed. All reported cases for 1985 involved facial and/or hand
contamination that was reduced to background levels by routine soap and
water cleansings.
Licensee personnel indicated th t the contamination
report form would be revised to include a reminder for a whole body count
for any contaminations greater than 10,000 dpm above the neck.
Nasal
smears and whole body counts are routinely conducted in these cases.
Clean trash is segregated from contaminated trash on the controlled side.
The clean trash is frisked daily by C/RP personnel before disposal into a
locked dumpster for offsite release.
These surveys are noted in the HP
logbook; dumpster keys are positively controlled by C/RP personnel to
prevent inadvertent release of contaminated trash.
No problems were noted.
No violations were identified.
S.
Transportation of Radioactive Materials
The inspector reviewed the licensee's transportation of radioactive
materials program, including:
determination whether written implementing
procedures are adequate, maintained current, properly approved and
acceptably implemented; determination whether shipments are in compliance
with NRC and 00T regulations and the licensee's quality assurance program;
determination if there were any transportation incidents involving
licensee shipments; adequacy of required records, reports, shipment
documentation, and notifications; and experience concerning identification
and correction of programmatic weaknesses.
Two radwaste shipments have been made since April 1984; LSA material was
trucked to Hanford in October 1984 and a High Intensity Container (HIC)
was shipped to Barnwell in February 1985.
An increased number of shipments
is planned for the rest of 1985 in anticipation of possible burial site
closures January 1, 1986.
Shipping papers reviewed were in accordance with
applicable regulations; survey readings were within limits.
Station QA
representatives complete an activity inspection checklist for each shipment
verifying shipping papers, survey procedures, instrument calibrations, and
vehicle integrity.
No transportation incidents were noted.
No problems
with standing water were identified.
The inspector previously reviewed licensee methods used to assure packages
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are in an unimpaired physical condition before shipment .
According to
the radwaste supervisor, the attending C/RP technician visually inspects
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IE Report No. 50-409/84-14
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drums and LSA boxes before shipment in accordance with Procedure RM-50,
Solid Radioactive Waste.
Filled drums and boxes are stored in the
radwaste building.
Empty LSA boxes are stored outside this building on
a concrete pad. Maximum storage time is approximately one year, estimated
by the radwaste supervisor.
The inspector observed eighteen boxes outside
that had been received during the first quarter 1985; no corrosion was
observed around the seal that would effect the sealing surface.
Station
QA staff inspect the empty drums and boxes upon receipt.
No violations were identified.
6.
Solid Radioactive Waste
The inspector reviewed the licensee's solid radioactive waste management
program, including:
determination whether changes to equipment and
procedures were in accordance with 10 CFR 50.59; adequacy of implementing
procedures to properly classify and characterize waste, prepare manifests,
and mark packages; overall performance of the process control and quality
assurance programs; adequacy of required records, reports, and notifica-
tions; and experience concerning identification and correction of
programmatic weaknesses.
Solid radwaste handling and storage facilities are located in the
radwaste building, bounded by a chain link fence outside the protected
area.
Building keys are positively controlled by the RP/ Chem department.
The inspector briefly observed compaction of dry active waste in
accordance with Procedure RM-50, Solid Radioactive Waste. Measures were
taken to minimize free standing liquid and volume.
No problems were
noted.
Filled LSA boxes and DAW compacted drums are stored in the southeast
section of this building.
During a routine survey on May 1, 1985, the
licensee noted increased readings (maximum of 0.8 mR/hr) at the chain
link fence inside the owner controlled area.
Readings decreased to
0.1-0.2 mR/hr following rearrangement of the drums and boxes; these
values were independently verified by the inspector with an NRC survey
instrument.
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Higher activity resins and filters are loaded into HICs from steel liners
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with limited personnel handling.
Exposure credited to 1984 radwaste
activities under the applicable RWP was 5.2 person-rem, approximately 4%
of the station total.
HICs are stored in three vaults in the radwaste
building before shipment.
Total radwaste inventory, volume, and
production are tracked monthly.
As of April 13, 1985, 403 Ci remained
onsite, approximately 10% of Technical Specifications 6.5.4.c inventory
limits.
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No violations were identified.
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7.
Staff Stability
The inspector reviewed the radiation protection and chemistry department
staffing and its impact on routine operations and the ALARA program.
A
relatively high technician turnover rate has occurred since October,
1984; six of the twelve technician positions have been vacated since
then.
Three technicians transferred to other positions within the
company; one was promoted to an RP/ Chemistry supervisor position; and
two left the company.
The licensee is actively screening and hiring
candidates.
Currently, nine technicians qualified for backshif t coverage
are available.
The RP/ Chemistry superintendent noted a 15-20% overtime
average over the past few months because of the reduced staff.
A new
schedule with alternating backshift coverage has been implemented for the
rest of CY 1985.
No adverse impact on the routine radiation protection
program was noted; however, overtime is necessary to cover nonroutine
operations.
This was discussed at the exit meeting.
HP contractor reliance is minimal; contractors are routinely procured
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only during an outage.
Attempts are being made to retain a previously
used contractor vendor for the upcoming outage.
Staff qualifications are comparable to industry norms .
Individual jobs
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are assigned to technicians based on qualifications and experience, and
exposure /ALARA considerations.
No apparent violations were identified.
8.
Facilities and Equipment
The inspector toured radiation protection facilities, observed radiation
protection equipment in use, and discussed plans for additional facilities
and equipment with health physics staff.
Currently, respirators are cleaned in a sink in the health physics / access
control area.
According to a licensee representative, approximately
twelve respirators can be cleaned at one time.
During outages, this
limited cleaning capacity affects respirator availability negatively.
A
facility change has been submitted to locate a respirator cleaning
dishwasher near the laundry facilities on the turbine deck.
This change
is scheduled to be completed by the September 1985 outage.
The licensee's
respirator inventory appears adequate.
This sink is also used for minor personal decontaminations.
Effective
decontamination practices were observed during this inspection.
Licensee
representatives stated the sink is cleaned after use; no significant
cross contaminations were noted.
A complete decontamination shower is
located near the health physics / access control area.
No violations were identified.
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IE Report No. 50-155/85003
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9.
Off Gas Releases
The licensee continues to track elevated off gas releases resulting from
leaking fuel bundles.
A decrease in mid-May to 1500 uCi/sec (150 MW
thermal) was noted in comparison to a maximum of 4,000 uCi/sec (200-220 MW
thermal) in mid-February.
A more gradual increase was noted during the
first and second quarters of 1985 over the third and fourth quarters 1984.
All values were within the Technical Specification 6.5.4.a limit of one
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curie per second.
No violations were identified.
10.
Recirculation Pump Area Entry
The inspector reviewed two personnel entries made May 1, 1985, into the
recirculation pump area, a high radiation area, to visually inspect a
suspected leaking seal.
The entries were made in accordance with
applicable procedures.
Reactor power was reduced to a steady state at
12 MWe, approximately 20% of full power.
The shift engineer and
maintenance supervisor were accompanied by a senior radiation technician
with neutron and gamma survey instruments.
Respirators were worn and
appropriate MPC hours assigned, as independently verified by the
inspector.
Total dose for the entries was 0.184 person-rem.
A prejob
briefing was held to discuss RWP requirements, ALARA considerations, and
dose estimates derived from previous entries.
The control room was
notified and key control maintained.
No violations were identified.
11.
Procedural Review
The inspector reviewed the following radiation protection and radwaste
procedures for regulatory adherence.
No problems were noted.
RP-2/Rev. 6
ALARA, Pre-Job Planning
RP-3/Rev. 8
ALARA Work Document Preparation and Review
RP-5/Rev. 10
Radiation Work Permit
RP-6/Rev. 6
Female Employees
RP-8/Rev. 9
High Radiation Area Key and Access Control
RP-9/Rev. 3
Contamination Control
RP-10/Rev. 10
Respiratory Protection and Airborne Contamination
Guides
RP-11/Rev. 2
Radioactive Material Control
RP-12/Rev. 3
Plant Visitors - Exposure Accounting
RP-13/Rev. 1
Instructions of Worker's Responsibility Concerning
Radiological Conditions
RM-50/Rev. 7
Solid Radioactive Waste
RM-51/Rev. 1
Radiological Safety Requirements for Pumping Spent
Resin From Disposal Tank to Concentrated Waste Tank
RM-53/Rev. 13
Radioactive Materials Shipment
RM-55/Rev. 6
Transfer of Spent Resin
No apparent violations were identified.
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12.
IE Bulletin 84-03:
Refueling Cavity Water Seal
The onsite technical engineering staff reviewed this IE bulletin describing
failure of pneumatic refueling cavity water seals to determine if this
design were applicable to Big Rock Point.
The evaluation concluded this
type of failure and resulting flooding was not applicable because:
(1) the
BRP seals were of a different design from those described in the Bulletin
and (2) the spent fuel pool is physically isolated from the reactor cavity.
13.
Exit Meeting
The inspector met with those noted in Section 1 on May 17, 1985 to discuss
the scope and findings of the inspection.
The inspector also discussed
the likely informational content of the inspection report with regard to
documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents / processes as proprietary.
In response to the inspector's comments, the licensee:
a.
Stated they would petition NRR for an alternative disposal method
pursuant to 10 CFR 20.302.
This commitment responded to the
inspector's comments that the licensee had not effectively addressed
this issue in the past, nor had the licensee acted in a timely
manner to inform NRR or Region III of their actions to resolve this
matter (Section 3).
b.
Stated that they would contact Region III by mid-June regarding their
respirator policy (Section 3).
c.
Acknowledged the reduced RP/ Chem technician staff and stated their
intent to procure qualified candidates (Section 7).
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