ML20133C523

Insp Rept 50-155/96-11 on 961202-06.Violations Noted.Major Areas Inspected:Radiological Protection & Chemistry Controls,Status of Rp&C Facilities & Equipment

ML20133C523
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133C483	List: ML20133C478 ML20133C511 ML20133C523
References
50-155-96-11, NUDOCS 9701070209
Download: ML20133C523 (9)

See also: IR 05000155/1996011

Text

'

.  !

1

.

.-

l U.S. NUCLEAR REGULATORY COMMISSION

f REGION lli

4 Docket No: 50-155

License No

DPR-06

i

.

Report No: 50-155/96011(DRS)

!.

.

Licensee: Consumers Power Company

. Facility: Big Rock Point Nuclear Plant ,

.! - 1

,

Location: 10269 U.S. 31 North ,

Charlevoix, MI 49720 l

l

Dates: December 2-6,1996 )

Inspectors: N. Shah, Radiation Specialist i

l

Approved by: T. Kozak, Chief, Plant Support Branch 2

Division of Reactor Safety

-)

i

!

,

l

I

1

1

i

i

9701070209 970102

PDR

G ADOCK 05000155

pg

_

_.__ - - _ _ . - - _ ..

.

'

_

Reoort Details

R1 Radiological Protection and Chemistry (RP&C) Controls

R 1.1 Solid Radioactive Waste (Radwaste) ar.d Transoortation Proarams

a. Insoection Scone (86750,2515/133)

The inspectors reviewed the licensee's solid radioactive waste and transportation l

programs as described in the Final Safety Analysis Report (FSAR) and Process l

'

Control Program (PCP). Annual individual dose totals received by the radwaste

workers from activities conducted through December 1996 were also reviewed.

b. Observation and Findinas

As described in the PCP, generated radwaste inc!uded dry active waste (DAWl,

spent resins, and filters. The licensee dewatered resin and filters onsite and sent

DAW to an offsite contractor for processing (compaction /supercompaction and

incineration). Waste not immediately sent to burial was stored in the radwaste

storage building (RWSB), which remained as described in NRC Inspection Report

(IR) Nos. 50-155/92011 and 50-155/93026. The inspector reviewed the results of

routine, quarterly inventories of items stored in the RWSB; no problemr. re

identified.

The inspector verified that the vendor system used for resin dewatering was

operated in accordance with an NRC approved topical report and that required

maintenance and functional tests were performed in accordance with vendor

procedures. Additionally, selected system performance criteria were reviewed to

verify that the processed radwaste met 10 CFR Part 61 requirements for waste

stability.

Scaling facto": for 10 CFR Part 61 waste characteriza cn analyses were generated

based on rcutme sampling of DAW, resin and filter waste streams. These samples

were sent to an offsite vendor for analysis and the results of the analysis were

reviewed by the Palisades Nuclear Plant health physics staff Based on that review,

the Palisades staff then generated scaling factors for use in Big Rock Point waste

characterizations. The inspector reviewed the past and current scaling factors used

by the licensee; no problems were identified.

Since burial site access was reinstated in mid 1995, the licensee shipped about

1500 ft 8of resin / filters and 6500 ft8of DAW for burial. This included the majority

of the waste stored in the RWSB, although there still remained an inventory of

1340 ft 8of resin / filters and 1600 ft 8of DAW. Licensee personnel were trainea in

the revised Department of Transportation (DOT) regulations and, during interviews,

demonstrated knowledge of these requirements. Additionally, the licensee complied

with GL 95-09 (and associated supplements). The licensee classified waste

shipments using a vendor software program, which the inspector verified was

updated to include the revised DOT requirements. The inspector selectively

reviewed shipment records and verified that they were consistent with the

2

0

,

regulations, that radwaste was properly classified and that the shipment departure  ;

and receipt times were appropriately logged. '

-

However, the inspector identified several problems with the technical oversight of

the radioactive waste program. Specifically, interviews revealed that neither the

current nor the former radwaste shipping supervisor recognized the purpose or

requirements of the PCP, the licensee's shipping staff was not aware of the review

criteria used by the Palisades health physics staff to generate the scaling factors,

and numerous examples were identified in the above shipping procedures where

.

either the incorrect or nonexistent regulatory requirements were referenced.

The inspector noted that these weaknesses were being compensated for by the

j

'

experience level of the staff and, through discussions with the licensee, were

caused by poor communication of program requirements by RP management to the

implementing staff. The licensee planr.ed to provide training to the staff regarding

program requirements and to revise the affected procedures.

Through December 1996, the average annual individual dose for radwaste workers

ranged from 1.8-1.9 rem compared to the licensee's administrative limit of 2 rem.

3

This was somewhat higher than past totals and was attributed to the onset of j

'

shipping activities and the cleanup of the resin tank room (see IR No. 50-

155/96006). Contributing causes included: reduced use of contract workers for

radwaste activities; informal radwasta shipping plan for 1996; and less than

'

anticipated oversight by the station ALARA coordinator owing to other emergent  ;

work. Licensee plans to lower 1997 dose included the development of a formal '

shipping plan for 1997 (including consideration of ALARA actions for high dose

shipments) and increased oversight by the station ALARA coordinator. I

'

l

c. Conclusions

.

The licensee's radwaste and processing program was maintained consistent with

regulatory requirements, but the technical oversight of the program was in need of

improvement.

R1.2 Audits and Followuo of Events

a. Insoection Scooe (IPs 83750. 84750 and 86750)

The inspector reviewed nuclear plant assurance department (NPAD) audit PA-96-10

(dated April 22-May 16,1996) of the effluent and solid radioactive waste and

transportation programs, associated field monitoring reports (FMRs) and radiation

protection (RP) internal self-assessments of the shipping program (dated January 23

and February 16,1996). This review also focused on identified trends based on

findings documented in condition reports (CRs) Nos.96-574, 96-942 and 96-782.

< b. Observations and Findinas

The NPAD audit and RP self-assessments were technically sound and of good

quality. Through interviews, the inspector verified that the auditors were

knowledgeable of solid radwaste processing and shipping requirements. In

3

.

.

particular, the inspector noted that the use of previous or current RP personnel to

assist the NPAD group rcsulted in a good technical review. Through a review of

FMRs, CRs and interviews with RP and NPAD representatives, the inspectors

verified that corrective actions for the radwaste audit findings were timely and

thorough. However, the NPAD group had not identified those weaknesses

discussed in sections R1.1 and R2.1. This was discussed with the NPAD group,

who will review the inspector's findings against the NPAD audit criteria.

One notable audit finding concerned the timely updating of radiological survey

status sheets and RP logbook entries by radiation protection technicians (RPTs). l

The RPTs were performing required radiological surveys, but were not always l

documenting survey results or area posting changes in the RP logbook. However,

the audit did not identify problems where this had resu!ted in workers not being  ;

aware of area radiological conditions. Although this was considered a management l

expectation, it was not clearly required by station procedures and was not well l

understood by the RPTs. Because these weaknesses had existed for several years, l

the RPTs had become complacent with the misunderstood requirements. A task

group (comprised of RP management and RPT representatives) was formed to

develop corrective actions. These actions included revising applicable plant

procedures and providing remedial training to the RPTs regarding management ,

expectations for documentation of survey results. The licensee planned to review l

the effectiveness of these actions in a subsequent, routine NPAD audit. l

l

A review of the above CRs identified problems in worker performance and work )

planning which were similar to those documented in NRC IR No. 50-155/95010. I

'

Some examples included poor worker self-checking during resin dewatering

activities resulting in several workers being sprayed with contaminated water,

operator failure to verify a valve lineup resulting in an inadvertent transfer of water

to the No.1 Dirty Waste Receiving Tank from the Chemical Waste Tank, and poor

work planning resulting in the inadvertent siphoning of about 1000 gallons of water

from the Radwaste Concentrator Tank to the Spent Resin Tank room floor. These )

events indicated that worker performance and planning problems continued to exist

at the plant.

1

c. farldusions

The licensee audits of the solid radwaste and shipping program were generally

effective. A review of CRs indicated continuing problems with worker performance

and work planning, concerning radwaste processing activities, since 1995.

R2 Status of RP&C Facilities and Equipment

R 2.1 Solid Radwaste Processino Systems

a. Insoection Scooe (86750)

An inspection of the solid radwaste processing and storage areas and plant

radiological controlled areas was performed.

4

.

)

.

b. Observations and Findinas

Although the inspector observed good radiological controls in the majority of the

areas inspected, several examples of poor radiological surveys and postings in the

radwaste processing and storage areas were observed. Specifically:  !

l

e Big Rock Point Procedure No. RP-30, " Establishing Area Postings" (Rev. No.

12), Step 5.3.2 required that high radiation areas be conspicuously posted

with a standard magenta radiation symbol on a yellow background with the j

words " CAUTION, HIGH RADIATION AREA," and Step 5.7.2 required that '

areas having contamination in excess of 1,000 disintegrations per minute per

100 square centimeters of activity (beta / gamma) be conspicuously posted

with a standard magenta radiation symbol on a yellow background with the )

words " CAUTION, CONTAMINATED AREA." l

However, the inspector identified that high radiation area and contaminated I

area postings in the resin dewatering area of the resin shed had fallen. The l

most recent survey of this area (dated October 10,1996) indicated one

location with dose rates of 100 mrem /hr (at 30 cm) and average

contamination levels of 30,000 dpm/100 cm2. The licensee indicated that

the radiological conditions were unchanged since the last survey and did not

identify any personnel who had inadvertently entered the area.

e Big Rock Point Administrative Procedure No. 5.11, " Radioactive Material

Control" (Rev. No.13), Step 5.4.3.1 required that all containers of i

radioactive material be labeled with a visible label bearing the radiation

symbol and the words " CAUTION, RADIOACTIVE MATERIAL." The label

and container shall provide sufficient information to permit individuals

handling, using, or working near the containers to take precautions to

minimize exposure. I

However, the inspector identified that 6 of the 16 DAW boxes stored in the

RWSB were incorrectly labeled as having dose rates of less than 5 millirem

per hour (mrem /hr) on contact. Big Rock Point Administrative Procedure No.

5.11, " Radioactive Material Control" (Rev. No.13), Step 5.4.3.1 required

that all containers of radioactive material be labeled with a visible label

bearing the radiation symbol and the words " CAUTION, RADIOACTIVE

MATERIAL." The label and container shall provide sufficient information to

permit individuals handling, using, or working near the containers to take

precautions to minimize exposure.

The inspector measured contact dose rates aetween 20-40 mrem /hr on 4 of the

boxes and between 100-120 mrem /hr on 2 of the boxes. These measurements

were subsequently verified by the licensee. Based on discussions with the licensee,

the incorrect labels may have been in place for several years.

The above problems were considered a violation of Technical Specification (TS)

No. 6.11 which required adherence to RP procedures (VIO 50-155/960:1-

01(DRS)). The licensee indicated that the poor labeling of the DAW boxes resulted

from complacency among the RP staff regarding acceptance of these conditions

5

'

,

)

.

and weaknesses in the radiological survey program. In particular, the DAW boxes

were last surveyed by an RPT (several years ago) who was since terminated for

poor performance. Although no prior, similar problems were identified, the radiation

protection manager indicated that surveys performed by this individual would be  !

verified as accurate. Subsequent routine monthly radiological surveys of the  !

RWSB, by other RPTs, failed to identify the discrepancies. Other planned corrective i

actions included revising applicable station procedures to verify labeled information '

with actual readings and providing training on these requirements to the RPTs.

c. Conclusions '

l

'

One violation was identified for failure to follow station procedures regarding

radiological posting and surveys in radwaste processing and storage areas.

R2.2 Documentation of Past Radioloaical Events Per 10 CFR oart 50.75(a)

a. Insoection Scoce (84750)

The inspector reviewed the licensee's documentation of spills or other similar

events involving the spread of contamination in or around the facility as required by

10 CFR Part 50.75(g).

b. Observations and Findinos

The licensee has two areas that were approved under 10 CFR Part 20.302 l

requirements. These areas include a location on the beach northeast of the plant ]

(approved for dredging, but not in use) and one in the general area of the ]

condensate tank extending beneath the turbine building floor (stillin use owing to l

subsequent leakage). The inspector verified that the licensee maintained

appropriate documentation of these areas and were meeting the record keeping

requirements discussed in NRC Information Notice No. 96-47.

As part of the Decommissioning Plan development, the licensee identified six -

events that required documentation per 10 CFR Part 50.75(g). Briefly, these

events were:

• On November 20,1980, about 10 ft 8of contaminated resin was spilled on

the pipe tunnel floor. The contaminated material was removed and disposed

as radioactive waste. At the time of disposal, residual contamination in the

area was about 8E-5 uCi/gm.

• On September 8,1981, during construction of the RWSB, construction

residue having low levels of contamination was disposed as radwaste. The

affected areas were decontaminated to below environmental lower limit of

detection (LLD) levels.

• On May 30,1984, the licensee identified leakage from an underground line

carrying makeup water from the condensate storage tank. Although the

majority of the affected soil (having low levels of tritium and iodine-131

6

'

.

)

,

contamination) was disposed of as radwaste, about 37 uCi of activity was

retained in the area under 10 CFR Part 20.302.

o On February 13,1987, water leaking from the #1 Waste Hold Tank resulted

in low levels of contamination in the ground underneath the tank. The

ground was decontaminated to levels below environmental LLDs and the

affected soil was disposed as radwaste.

I

• On November 27,1993, leakage from an above ground demineralizer fillline

to the condensate storage tank resulted in low levels of contamination in the

soil below the line. The affected soil was removed and disposed as )

radwaste. The remaining soil had activity below the environmental LLDs.

l

l

The inspector verified that the licensee had maintained the information documenting ,

these events (including disposal records and isotopic sampling and analysis results)

per the requirements of 10 CFR Part 50.75(g).

R.8 Miscellaneous RP&C issues

R8.1 (Closed) Review of Unresolved Item (URI) No. 50-155/96008-04

The inspector reviewed the licensee's corrective actions for the above URI,

concerning the failure to perform an adequate radiological survey which did not  !

identify contamination prior to the free release of a truck from the RWSB. The  ;

event occurred in October 1996, and was also documented in licensee CR No. 96- l

885. The truck was subsequently decontaminated and the bedliner removed. I

Based on isotopic analysis of activity found on the truck bed, the licensee l

concluded that the contamination came from a bagged, contaminated hose which '

the truck was carrying on October 3,1996. Corrective actions included discussing i

the event and the radiological survey requirements with the radwaste handlers and  !

RP, chemistry and dosimetry technicians involved in radwaste activities.

Although this event was identified by the licensee, the inspector noted that the

contamination levels on the truck (20,000 dpm/100 cm 2) were readily detectible

had a reasonable survey been performed. The inspector also identified that a i

similar concern, regarding a free release survey for a " boom truck," was

documented in FMR No. FM-B-96-125 (dated 5/23/96), for which corrective actions

were apparently not effective. Therefore, the October event was considered

another example of non-compliance with TS 6.11, for failure to follow the

Station Procedure No. RM-56 " Radiological Clearance For Offsite Removal of

Material" which required that all material having clean status shall have no activity

detected either by direct frisk or shall successfully pass through contamination

monitors (see Section R2.1) (VIO 50-155/96011-01).

X.1 Exit Meeting Summary

The inspector presented the inspection results to members of the licensee

management at the conclusion of the inspection on December 6,1996. The

licensee acknowledged the findings presented and did not identify any of the

documents reviewed as proprietary.

7

._ - . . _ _._ __. _ .. _ . _ _ _ _ - . _ _ _ _ _ ... _ _ _ . _. _ .. _ _. .. _ . _ _ . _ _ > _ . _

.

.

1

PARTIAL LIST OF PERSONS CONTACTED

4 l

)

Licensee

)

j- P. M. Donnelly, Plant Manager

'

R. Addy, Assistant Plant Manager l

I W. Barnshaw, Lead Resident Assessor, NPAD

l

1 E. A. Bogue, Training Manager

1

M. Bourassa, Licensing Supervisor

,

5  !

L. Darrah, Operations Supervisor  !

4

D. D. Hice, Maintenance Manager

] . W. Hoaglund, Radioactive Waste Shipping Supervisor

T. Mosley, Senior Engineer--Chemistry and Health Physics '

_

K. E. Pallagi, Chemistry and Health Physics Manager  !

j' J. Tilton, Electrical and Instrumentation Engineering Supervisor

D. Turner, Decommissioning Team Leadei l

! )

J. Werner, NPAD Assessor '

j - G. C. Withrow, Plant Safety and Licensirig Director l

I

i

! E l

R. Leemon, Big Rock Point Senior Resident inspector

j C. Brown, Big Rock Point Resident inspector

.

!

INSPECTION PROCEDURES USED

i

'

! IP 83750 Radiation Protection Program

j lP 86750 Solid Radioactive Waua and Transportation

Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71

ITEMS OPENED, CLOSED AND DISCUSSED

Opened

Violation No. 50-155/96011-01 Failure to Adequately Post and Survey

Radiological Areas

Closed

Unresolved item No. 50-155/96008-04 Failure to Adequately Survey a Truck Prior to

Free Release (Closed as Violation No. 50-

155/96011-01 above).

8

. _ . ,. . . _ - .- - -. .

~

,

.

PARTIAL LISTING OF DOCUMENTS REVIEWED

Process Control Program for Solid Radioactive Waste (dated 1/22/96)

l NRC Generic Letter 95-09 (and associated Supplements) " Monitoring and Training of

l Shippers and Carriers of Radioactive Materials".

,

Station Procedure Nos.:

RM-53 (Rev. No. 30, dated 7/8/96) " Radioactive Material Shipment"

RM-58 (Rev. No. 5, dated 6/29/95) " Packaging of Radioactive Waste for Shipment to

<

Scientific Ecology Group (SEG)"

RM-50 (Rev. No.18, dated 10/23/96) "Redioactive Waste"

]

l RP-30 (Rev. No.12, dated 11/20/95) "Estab!ishing Area Postings"

l

l RM-56 (Rev. No.14, dated 6/29/95) " Radiological Clearance for Offsite Removal of

Material"

. Administrative Procedure No. 5,11 (Rev. No.13, dated 7/31/96) " Radioactive Material

Control"

.

i Radioactive Shipment Nos: S-1513,S-1525,S-1506, S-1526, S-1482

Nuclear Performance Assessment Audit (NPAD) No. PA-96-10 (dated April 22-May 16,

1996)

,

Condition Report (CR) Nos:

96-942 " Overflow of Chemistry tank to the #1 Dirty Waste Receiving Tank (DWRT)"

4

!96-782 " Siphoning of Approximately 1000 gallons of water from the Radwaste

Concentrator Tank"

~

96-564 " Pressurization of High integrity Container Return Hose" i

?

l

, 96-8G5 " Contamination Found in Bed of 2x4 Truck"

)

I 1

NRC Information Notice No. 96-47 "Recordkeeping, Decommissioning Notifications for j

Disposals of Radioactive Waste by Land Burial Authorized under Former 10 CFR 20.304, i

'

20.302 and Current 20.2002." l

Big Rock Point Site Decommissianing Plan (Rev. No. 0) Section 3, " Facility Radiological

Status." l

l

9

i