ML20126K354

Insp Rept 50-155/85-08 on 850513-17.No Apparent Violations Noted.Major Areas Inspected:Radiation & Radwaste Programs, Including Control of Matl,Transportation,Solid Radwaste, Staffing & Response to IE Bulletin 84-03

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: ML20126K334 ML20126K354 ML20127D617
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 4//2 df

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Approved By: L. R. Greger, Chief 4//2//f

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.

._ (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 ,

members of the fire brigade and radiation protection technicians, to wear

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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

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respirator / facial hair policy is under review by licensee management.

Licensee representatives committed to contact Region III by mid-June i

! regarding the conclusions of that review.

(0 pen) Deviation (155/85003-02): Feilure to implement Sections X and XI

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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

! program. The health physics department had not responded to the

{ findings. This item will be further reviewed.

{ 4. Control of Radioactive Materials and Contamination

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The inspector reviewed the licensee's program for control of radioactive

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

{ of review and dissemination of survey data; and effectiveness of methods

l of control of radioactive and contaminated materials.

In general, a threshold level of 400 dpm/100 cm 2 is used for decontamina-

l tion. Contaminated areas greater than 400 dpm/100 cm2 that cannot be >

l 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%

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of the controlled area is boundaried. Survey data reviewed indicated

general area smears of the controlled area below the 400 dpm/100 cm 2 1,ye1,

! The highest smearable contamination was consistently found at the reactor

j deck, a boundaried area.

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The licensee has established a routine decontamination program. General

areas of the sphere are deconned monthly. Under a recent policy

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implemented in late 1984, higher contaminated areas are identified and

scheduled for decontamination. Four decontamination lockers have recently

been positioned throughout the plant to increase availability of supplies.

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Management is reviewing this policy to determine its effectivenss.

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

are in an unimpaired physical condition before shipment1 . 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.

! Higher activity resins and filters are loaded into HICs from steel liners

! 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

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limits.

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.

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HP contractor reliance is minimal; contractors are routinely procured

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 norms2. Individual jobs

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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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.

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All values were within the Technical Specification 6.5.4.a limit of one

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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