ML20141J995

From kanterella
Jump to navigation Jump to search
Insp Rept 50-155/97-05 on 970303-0428.Violations Noted. Major Areas Inspected:Event in Which Workers Entered Power Block While Reactor at 9% Power Level Prior to Performance of Adequate Evaluation of Area Radiological Conditions
ML20141J995
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/19/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141J973 List:
References
50-155-97-05, 50-155-97-5, NUDOCS 9705280280
Download: ML20141J995 (14)


See also: IR 05000155/1997005

Text

._ _ . _ _ . _ . . _ . _ _ - . _ . . . _ _ _ _ _ _ . _ . . - _ _ _ . . .. . . . _ _ . . _ _

. ,

,

j .

J

' l

'

U.S. NUCLEAR REGULATORY COMMISSION

,

REGION lli ,

,

t

i i

'

Docket No: 50-155  ;

Licenae No: DPR-06 i

!

Report No: 50-155/97005(DRS)

i -

!  !

Licensee: Consumers Power Company

!

.

Facility: Big Rock Point Nuclear Power Plant l

,

Location: 10269 U.S. 31 North

Charlevoix, MI 49720

Dates: March 3 - April 28,1997

Inspectors: R. A. Paul, Senior Radiation Specialist

G. W. West, Radiation Specialist

Approved by: Thomas J. Kozak, Chief, Plant Support Branch 2

'

Division of Reactor Safety

9705280200 970519

PDR ADOCK 05000155 ~

G PDR .

--

. . --. - . - . - . - . - .- . . - . - - - - - . - - . - .- - - .-. --

. .

.

EXECUTIVE SUMMARY

Big Rock Nuclear Power Plant

NRC Inspection Report 50-155/97005

The inspectors reviewed an event in which workers bntered the power block while the

reactor was at 9% power level prior to the performance of an adequate evaluation of the

area's radiological conditions, and reviewed a separate but related event that resulted in I

the spread of contamination throughout the turbine building. Also reviewed was an event

in which a station engineer who was not qualified to enter high radiation areas without

accompaniment by a radiation protection technician (RPT), entered a HRA on two

occasions without an RPT. . These events resulted in the identification of three apparent

violations which are described in detail in the enclosed report, and are being considered for

escalated enforcement. The common cause of the apparent violations, which includes the

failure of licenses staff to adequately plan for jobs and to adequately evaluate radiological i

conditions in job areas, indicates radiological programmatic deficiencies in the areas of pre- j

Job planning, ALARA planning, and radiological assessment. Workers also exhibited a lack  ;

of sensitivity towards radiation protection controls during these events.

In addition to the events, a review of the radiological environmental monitoring program

and the liquid and gaseous radioactive waste processing programs was performed and no

significant problems were identified in these areas.

l

l

!

l

2

- .. .. . . - - _ - - - . - _ . -

.

4

Renort Details

IV. Plant Suonort

R1 Radiological Protection and Chemistry Controls

R1.1 Control of Rac'ioloolcal Work Activities

a. Insoection Geone (83750)

Using inspection Procedure 83750, the inspectors reviewed the circumstances

surrounding the entry of two individuals into the power block to perform inspection

of the equipment in the area for steam leaks (tour event), and a separate but related

event in which contamination was spread throughout the turbine building while

disposing of contaminated waste processing filters (filter event!. The inspectors

also reviewed the circumstances surrounding the entry of an unqualified individual

into a high radiation area (HRA) without specified procedural controls.

b. Observations and Findinas

Tour Event

On February 2,1997, two workers performed the grand tour in the power block. A

number of problems, which are detailed below, occurred during this job. These

problems were either self-identified in a licensee root cause evaluation or were 44

revealing during the event. The inspectors' independent review of the event

determined that the licensee had accurately assessed the event and the problems

which were encountered in their root cause evaluation. The specific details of the

event are described below.

After a plant shutdown, the licensee performs a tour (known as the grand tour) of

the steam drum and piping areas within the power block to identify steam leaks

that may be present. This tour is normally performed at operating pressure and

with the plant at very low power levels (approximately 1 percent power). Personnel

normally enter at an upper elevation (steam drum level) and proceed down about

three levels via a ladder and out of the area. Dose rates typically encountered

during the tour are less than 2 rem /hr gamma with no appreciable neutron dose

rates.

The licensee was in the final stages of an outage during which main steam isolation

valve work was conducted. Surveillance testing of the valves was required to be

performed with the reactor at approximately 8 MWe (9% power). The operations

department determined that it would be most efficient to perform the grand tour in

conjunction with the MSIV surveillance testing. Radiation protection supervision

was not involved with this decision which indicated that they were not adequately

involved in the job planning process.

3

. _ _ _ . _ _ - - _ _ _ . _ _ . _ _ . _ . _ _ _ _ _ _ _ . _ . - .._._._ _ _ _ _ . _ _ _. _ _ _

t

( .'.

i

j .

,

The normal entry from the steam drum area was locked; therefore, it was  !

necessary to enter the power block from the recirculation pump area in the lower ,

level, up the ladder to the stecm drum and then back down the ladder. The revised

path required traversing the HRA areas twice, thus effectively increasing personal  :

! dose. Although the radiological conditions were expected to be worse than those

j normally encountered during the tour, the workers associated with the job did not

appropriately address these differences during the planning stages or the briefings

l for the job. The radiation work permit covering this activity was not revised '

beforehand to reflect the different radiological conditions which exist during 9%

power operations, nor were the electronic dosimeter (ED) alarm setpoints changed

to accurately reflect expected dose and dose rate levels. The projob planning and

j' briefing did not address historical data for the radiological conditions at this power

'

) level or special ALARA considerations such as the appropriate tour route. This ,

i- represented a failure to appropriately evaluate the potential radiological hazards

associated with the job.

t

l The tour was performed by a shift supervisor (SS) who was accompanied by a

j senior radiation protection technician (RPT). The RPT had a dose rate meter but it  ;

was dark and very difficult to see. At about the midpoint of the climb up the

ladder, both person's EDs alarmed for a high dose rate. The RPT did not check the  ;

i dose rate meter at this time. They continued up the ladder to a platform where the

RPT indicated that they had to leave the area per procedure. However, after a

i discussion with the SS,it was decided that it would be ALARA to complete their

j tour because the inspection would still have to be completed another time, causing l

.

additional dose. The RPT checked his dose rate meter and determinad dose rates .

l- were approximately 4 rem per hour on the platform. This was the only time during l

l the tour that dose rates were verified. Sometime between receiving the dose rate i

i alarm and arriving at the platform, the individuals' preset accumulated dose alarm

j activated. The individuals proceeded up to the steam drum area, performed the

required inspection and then proceeded down the ladder and out of the area. The

workers immediately reported the ED alarms and their thought process in a

i condition repcrt (CR) upon exit from the area. i

!

! Based on TLDs for each of the workers their accumulated whole body exposure,

i' including neutron dose, was 273 mrem and 341 mrem respectively. The

!

'

corresponding dose from gamma exposure recorded on the EDs was 245 mrem and

315 mrem respectively, and the maximum gamma dose rate for each individual was

6880 mrem and 7050 mrem respectively. The ED histogram also indicated dose

rates during the tour ranged up to 5 rem /hr (0.05 Sv/hr) to 7 rem /hr (0.07 Sv/hr)

and the tour took about 17 minutes. The inspectors evaluation of the whole body

exposures indicated the results were reasonably consistent with the varying dose

rates and the times recorded on the ED histogram.

i

10 CFR Part 20.1501, requires licensee's to make surveys that are reas,onable

under the circumstances to evaluate the extent of radiation levels and the potential

radiological hazards that could be present. The failure of the workers to evaluate

the extent of radiation levels and the potential radiological hazards that could be

present (gamma dose rates ranged up to 7 rem / hour and the neutron dose rates

4

. ., -

. _ ..

1

,

.

ranged up to 1.5 rem / hour during the grand tour) to ensure compliance with 10 CFR

20.1201(a)(1), is an apparent violation of 10 CFR 20.1501(a) (eel 50-155/97005-

01a). I

1

l

Failure to exit the HRA after receiving electronic dosimetry alarms during the grond 1

tour is an example of an apparent violation of Technical Specification (TS) 6.11. l

This TS refers to Administrative Procedure 5.8, "High Radiation Area Key and j

Access Control," Revision 10, which requires in Step 5.1.f.7. that a HRA be l

. immediately exited on either an ED dose or dose rate alarm (eel 50-155/97005- )

02a).

In addition to the apparent violations which occurred during the entry, the coverage

provided by the RPT for the job was poor. The individuals had a dose rate meter

l

end thus met the TS requirements for control of high radiation area entries.

'

However, the meter was not periodically read and the individuals only determined  :

the actual area dose rates on one occasion during the tour. Therefore, they were  !

not always aware of the radiological conditions in the area and did not detect the

highest dose rate that they actually experienced. Licensee management indicated

that this performance did not meet their expectations for high radiation area

coverage by an RPT.

i

a Several immediate corrective actions were taken after this event, including: Plant

i manager approval was temporarily required before performing work in HRAs and all

! RWPs required the HP manager's approval, the workers involved were disciplined, l'

!

accountability for procedural adherence was addressed with all plant personnel, and

a case study was developed on the lessons learned from this event and presented

,

to all station personnel. Other corrective actions included reorganization of the RP

! department to provide stronger oversight of RP related activities and ALARA

i planning; additional personnel were added to the management (including first line

l supervisors) delineating their responsibilities and authority in radiological decisions

i involving radiation safety and ALARA.

l

l The licensee's investigation also found that workers exhibit a casual

'

approach to radiation protection and RWP work practices which were

evidenced by the following identified weaknesses
the RWP had not been

updated for the expected dose nor did 'it characterize the actual radiological i

i conditions in the areas being inspected, including not clearly defining the  :

l neutron monitoring requirements or actual dose rates; the dose rate and EDL '

i alarms had not been raised and were inappropriate for the actual conditions; i

the ALARA and prejob planning and briefing were weak; and individuals

'

l involved in the evolution did not adequately review and understand the RWP

l conditions and requirements. ,

!

) Filter Event

i

'

On February 24,1997, loose radioactive surface contamination was spread

throughout the turbine building while radwaste handlers transferred depleted waste

l processing filters from a temporary holding barrel into a filter transfer cask. This

'

I 5

i

i

k

'

i i

.

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

i

!-

j

  • l

\

i

event was subsequently reviewed by the licensee and the problems assor.iated with 1

F it were self-identified during the event. The inspectors' independent review of the

,

event determined that the licensee had occurately assessed the event and the  ;

j problems which were encountered in their review. The specific datails of the event  ;

.

are desc.ibed below.

L >

4

The event occurred when two radwaste handlers were moving fih n from a l

j storage barrel into a transfer cask. To accomplish this, the radwuste processing ,

'

j area (RWPA) ceiling cover plug was removed so the workers L.ould remotely  ;

transfer the filters. .The plant ventilation system had been placed in a cold weather

configurd which required closing turbine building louvers and Tacirculating flow.

,

l The ff - not been previously transferred under this condition, in order to .

l

i- transkt < .cers, the workers had to capture them bv # stabbing / spearing action  !

with the pointed end of a long hsndled tool. The filters had been in the storage

[1 -

3

barrel for approximately one month and had dried out. The surface reading on the

,

l

barrel was about 32 rem /hr (0.32 Sv/hr). Contamination on the filter was disturbed l

. by the stabbing / spearing action during their transfer and the ventilation flow carried

3

the contaminated material to the turbine building.

!

l Contamination levels ranged from 300,000 disintegrations per minute (dpm) on i

i large area surveys (smears) in the turbine build 5g to 1,000,000 dpm on large area  ;

smears in the RWPA, primarily from cobalt-60. The highest beta dose rate on one  ;

l of the smears was approximately 320 mrad / hour (3.20 milli /Sv). Severalindividuals  ;

4 were slightly externally and intemally contaminated as a result of this event. The

[ cumulative personnel dose during decontamination activities was approximately 30

j millirem (0.3 milli /Sv) caused primarily from normal radiation dose rates in the areas  !

j decontaminated. Access was allowed to the area during the decontamination l

activities in accordance with licensee procedures and the decontamination of the  !

j affected areas was completed in about three days. Because there was no

i measurable increase in the stack particulate monitor during this event and no I

j contamination detected during surveys performed cutside of the plant, it appears

l there was no release of radioactive material to the environment.

!

! Although pre-job and ALARA reviews were performed prior to the filter transfer job,

insufficient attention was given to the changed plant and radiological conditions

j such as the ventilation system being placed in a cold weather configuration, higher

i than normal dose rates on the filters, and the longer storage time for the filters

i which allowed them to dry out making it much more likely that contamination

! would becorn airborne. Because HRA work was on hold, the fi!ters began to

[ accumulate in the RWPA causing the higher than usual dose Wes, and the filters

i had dried out for a month compared to a normal week or w % 4 significant 1

! airbome radioactive material condition resulted when the fh M " are transferred

j without the use of engineering controls. The failure to properly evaluate the

! potential radiological hazards associated with the transfer of the highly

contaminated filters is an additional example of an apparent violation of 10 CFR

} 20.1501(a). (EE1 No. 50-155/97005-01b).

1

4

i

i

6

)

.

4

!

L__-_____---__._____,_____ - _ _ - - -. - _ _ . - , . . - - - - _ _ . . _ - . , - - . - - - -

.-,1

,

<

,. l

j -

! The gaseous waste management system description in Final Hazards Safety Report

4- (FHSR), Section 11.3.2, states that air flow rates will remain sufficient to minimize

build-up of airborne contamination and that flows begin in radioactively clean areas

j

and are directed to potentially mere highly contaminated areas then exhausted to

-

the stack. Drawing number 0740G40124, which is referenced in FHSR Section

] 11.3.2, indicetes that air flows from the RWPA directly into the exhaust plenum

and out the plant stack. During this event, the air flow was reversed (from the

! ' RWPA through the turbine building, into the pipe tunnel, and out the main stack).

4

This flow was from an area of high contamination to ons of lower contamination

i levels. During the licensee's investigation of thu event, the damper on the RWPA

exhaust pleaum was found to be closed (this was not expected even in a cold ,

l weather configuration), thereby considerably restricting the air flow of the exhaust i

j system, which caused the flow to reverse. It was not determined when or how

'  !

long the damper had been closed. This modification to the air flow pathway was  !

O

not adequately analyzed. No design change nr 10 CFR 50.59 safety evaluation was

l

l performed to address the new ventilation flow path. This is considered an example {

of an apparent violation of 10 CFR 50.59 (eel No. 50-155/97005-03(DRS)). '

i

.

! )

Several immediate corrective actions were taken following this event, including: i

! the use of engineering controls will be specified for future evolutions of this nature, l

! the damper on the radwaste ventilation system was opened to establish design  !

! flow, and the method for transferring the filters was changed from a stabbing l

i action to a grasping action. Longer term actions include the balancing of statinn  !

-

ventilation airflows in accordance with design. l

l Unaualified Worker Entries into HRA 1

j On January 20,1997, the licensee identified that a station engineer who was not l

i high radiation area access (HRAA) qualified entered the reactor water clean up .

i pump room on two occasions. Although he was accompanied by an auxiliary '

] operator who was HRAA qualified, this was not in accordance with Administrative

!

Procedure 5.8.c, "HRA Key and Access Control," which states that entry into HRAs

is not allowed unless there are two persons, both of whom should be HRAA l

l qualified, and if one person is not, then he/she will be provideo with dedicated RPT

l coverage. The ares entered was posted and controlled as a HRA with some

! sections having general area dose rates in excess of 1 rem /br. The failure of the

non-qualified engineer to be provided with RPT coverage is an additional example of

j an apparent violation of TS 6.11 requirements that radiation protection procedures 3

J

be established and adhered to. (eel No. 50-155/97005-02b). j !

'

Several performance problems c ontributing to this apparent violation were noted,

j including: the engineer neither anderstood or knew the requirements for HRAA;

i there was no accurate list of HAAA qualified persons available; and operations,

j

'

radiation safety, and engineering personnel associated with this event did not have

a questioning attitude conce.ning the engineers qualifications. In addition to the

general corrective action.* caken to address the station issue of lack of sensitivity to

j radiation protection cor.trols, specific corrective actions for this incident included

l counseling of worke:s involved, briefings with the Health Physics staff concerning

I

7

L

4

.

,,n , ,- , -

_ _ .__ _ _ ___ _ __ _ _ _ . _ . _ _ . _ _ _ ___ _ _ _ _ _ _

.

4

)

counseling of workers involved, briefings with the Health Physics staff concerning

their responsibilities at access control, and the posting of an up-to-date list of HRRA

qualified persons at the access control.

c. Conclusions

The events revealed a number of problems in the radiation protection program

including a lack of effective supervisory oversight and involvement in radiologice.l I

work activities, a failure to adequately address the radiological implications e,i work

activities during the work planning stage, and a generallack of respect for

i radiological hazards and controls by the workforce. Although the events did not

result in a substantial potential for an overexposure, the failure to recognize the

potential radiological hazards present (filter event), the failure to specify appropriate

controls for the work when more severe radiological hazards were recognized to be i

2

present (tour event), and the failure to recognize the lack of qualification to enter

,

HRAs iridicates that significant weaknesses existed in the radiation protection

prograrn.

l The apparent violations identified above are being considered for escalated

enforcement action in accordance with the " General Statement of Policy and

4

Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600.

Accordingly, no Notice of Violation is presently being issued for these inspection

findings. Since the circumstances surrounding these apparent violations, the

significance of these issues, and corrective actions were discussed with the

4

licensee at the interim exit meeting for this inspection period on April 3,1997, a

predecisional enforcement conference may not be necessary in order to enable tho

l NRC to make an enforcement decision. Before the NRC makes its enforcement

l decision, the licensee will be provided an opportunity to either respond to the

apparent violations or request a predecisional enforcement conference, as described

in the cover letter to this report.

R1.2 Radioloaical Environmental Monitorina Proaram (REMP) and Liouid and Gaseous

Radwaste Processina

4

a. Insoection Scoos (IP 84750)

J

The inspectors reviewed selected portions of the licensee's liquid and gaseous

l radwaste program including radwaste discharge records and procedures, dose

j

'

quantification methodology, technical documents to determine compliance with

effluent requirements, effluent control instruments, accident monitor calibration

4

procedures and results, establishing ' monitor alarm set points, and discharge batch

releases. The inspectors also reviewed the REMP,

1

!

b. Observation and Findinas

There were two changes to the Off-site Dose Calculation Manual (ODCM) in

January 1996, which were adjustments to reflect an updated land use census.

Specifically, the distance values for residence / garden, cattle, and dairy cows (and

h 8

.

J

.--

. - - . - - - _ _ - - - . - - . . - - - . - - ~ ~ - _ _ - - - - . . - -

4

.

!

j goats) were updated, as were corresponding X/O computations. These changes

! were acceptable. Quantification of gaseous discharges was completed in

l accordance with the appropriate procedures and grab samples taken from the off-

4

gas system, which were used to quantify gaseous releases, were verified by the

, use of stack effluent monitor results.

3 No significant operability problems with gaseous radioactive effluent monitors

i required by Technical Specifications were identified. However, the licensee has had

l chronic problems maintaining isokinetic flow through the stack effluent monitor.

4

The flow through the instrument, which is needed to ensure accurate particulate

i readings, continues to be at the lower range of the licensee's design basis listed in

j the FSAR, and on several occasions the flow velocity had dropped enough for the

'

monitor to be declared inoperable. To ensure the T/S requirements were met during

! those times when the flow was lower than required, the licensee took

compensatory samples including periodic sampling of reactor coolant. The licensee

l has recently changed to a different type of particulate filter and has performed

, extensive analysis to determine the cause of this problem. At the time of the

j inspection, it appeared to be a design problem with the pumps pulling air through

! the instrument. The licensee planned to replace these pumps during the next

refueling outage. It appears that the licensee has taken appropriate actions to

review and correct this problem.

j

l All radioactive liquid batch effluent releases were evaluated by analysis of

} representative samples and released through a TS monitor, through a downstream '

i discharge canal monitor, and into Lake Michigan. One abnormal release occurred '

on March 2,1997, when a reactor operator attached a hose to the reverse osmosis

unit drain to transfer slightly contaminated water (about 1E-5 microcuries per

milliliter) to the drain under the caustic tank. This drain was one of two floor drains

in the condensate pump room which were plugged to prevent drainage to the Lake.

There was an obscured sign nearby stating that the drain should not be used for

disposal of contaminated liquids; however, this was not recognized by the operator.

Although this drain was plugged, the licensee discovered a small hole in the drain

bowl, leading them to believe that a minimal amount of water may have been

discharged to the concrete surrounding the line. Subsequent investigation

determined that the defect allowed the water (less than about 0.015 microcuries in

one liter) to leak under the condensate pump room floor. Immediate ccrrective

actions to prevent recurrence included strengthening of administrative procedures

used to control radioactive liquid transfers, training of personnel on those revisions

and performance of an engineerinc evaluation to evaluate other plant drains

susceptible to similar degradation and repair of those drains identified. The licensee

indicated that the contamination would be removed in the near future.

The inspectors walked down all TS-required process monitors and their condition

was good. The inspectors reviewed procedures, past calibrations, channel

functional checks, sources checks, and set point calculations for the TS effluent

monitors. All of the procedures were acceptable and were performed correcdy and

the documentation was complete. In addition, procedures had been appropriately

modified to correct for inspection followup item (IFI) 50155/95005-01(DRS),

9

. __ .- -- -

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

.

'

.

'

l

,

which involved a failure to account for the decay of a cesium-137 standard used in

the calibration of the liquid monitors (Circulating Water Discharge Process Monitor l

and Liquid Radwaste Effluent Monitor).

l

'

The inspectors observed the control room indications for the process and effluent

monitors and interviewed control room personnel about these monitors. The

recorders and indications were in good condition and personnel were comfortable

with monitor alarm procedures and wlth setpoint determination and adjustment on

these monitors. l

Inspectors reviewed the 1995 and 1996 Annual Effluent Reports and determined

that offsite doses were calculated in accordance with the ODCM. Generally, total

gaseous radioactive affluents were down about 30 percent (from 4902 Ci to 3490

Ci) for 1996, except for tritium, which was up substantially (127 percent). Total

liquid radioactive effluents were down about 15 percent (from 562 mci to 480

mci) for 1996, except for tritium, which was down about 43 percent. The licensee

attributes these trends to differences in operating history between 1995 and 1996,

as well as to decreased plant water (and thus tritium) leakage.

The inspectors reviewed a recent audit (January 1997) of the licensee's RETS

(Radiological Effluent Technical Specifications) and REMP. The audit found that the

licensee was effectively implementing the REMP/RETS program while meeting the

requirements of their applicable Technical Specifications, administrative and

working level procedures, and of 10 CFF1 Part 50, Appendix B. Three open items

addressed in the audit included a stack gas sampling instrument flow rate problem

(discussed in this Section; a lack of Chemistry / Health Physics improvements

documentation and self-assessment, and multiple occurrences of corrections on

sample data collection forms not being dated / initialled. Corrective actions for these

items was in progress.

c. Conclusions

Overall, the liquid, gaseous, control instrumentation, and REMP monitoring program

was effectively implemented. Radioactive releases and dose to the public from the

releases were well below the regulatory permissible limits. Quantification of

gaseous and liquid discharges were completed in accordance with the appropriate

procedures, and the inspectors established that offsite doses and effluent release

monitor setpoints were calculated using ODCM methodology. An incomplete

understanding of the liquid radwaste processing system led an operator to direct

slightly contaminated water to a plugged floor drain which in turn led to about one

liter of water to migrate to the concrete surrounding the drain line.

R8 Miscellaneous RP&C lasues

R8.1 (Closed) IFl 50-155/95005-01: failure to account for the decay of a cesium-137

standard used in the calibration of the liquid monitors. The calibration procedures

for the Circulating Water Discharge Process Monitor and the Liquid Radwaste I

10

!

l

_ _

.

T

4

Effluent Monitor have been appropriately modified such that the radioactive decay

l of the source is accounted for. This item is closed.

V. Management Meetings '

X1 Exit Meeting Summary I

l

!

The inspectors presented the inspection results to members of licensee management ,

during an interim exit meeting on April 3,1997 and at the conclusion of the inspection on j

'

April 28,1997. The licensee acknowledged the findings presented. l

!

The inspectors asked the licensee whether any materials examined during the inspection  :

should be considered proprietary. No proprietary information was identified. I

,

i

4 1

1

'

,

i

l

i

. I

4

!

l

I

-

l

i

1

'

'

l

l

i

11

!

)

,

O

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Addy, Plant Manager

W. Blosh, Maintenance Supervisor

M. Bourassa, Acting Licensing Manager

L. Darrah, Operations Supervisor

K. Pallagi, Chemistry / Health Physics Manager

T. Popa, Chemistry / Dosimetry Supervisor

K. Powers, General Manager

G. Withrow, Plant Safety and Licensing Director

INSPECTION PROCEDURES USED

IP 83750: Occupational Exposure

IP 84750: Liquid and Gaseous Radwaste

ITEMS OPENED and CLOSED

l

Ooened

50-155/97005-01(a,b) eel two examples of a failure to perform adequate

evaluation >

50-155/97005-02(a,b) eel two examples of a failure to follow procedural

requirements )

50-155/97005-03 eel failure to perform safety evaluation '

Closed

50-155/95005-01 IFl failure to account for the decay of a cesium-137

standard used in the calibration of the liquid monitors

Discussed

No open items were discussed

12

__ _ _ - - .

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

.

4

.  ;

} LIST OF ACRONYMS USED

ALARA As Low As Reasonably Achievable

HRA High Radiation Area

HRAA High Radiation Area Access

HP Health Physics

IFl inspection Followup item

IP Inspection Procedure

IR Inspection Report

LER Licensee Event Report

NOV Notice of Violation

NRC Nuclear Regulatory Commission

RO Reactor Operator

RP Radiation Protection *

RPA Radiologically Protected Area i

RPT Radiation Protection Technician  !

SS Shift Supervisor

TS Technical Specification

VIO Violation

l

.

'l

l

l

.

13

. - - . . - - -- - . - . . - . . - . - - . - . . . . - . . - - - - - - . - - -

! *

..

>

l LIST OF DOCUMENTS REVIEWED

1 inspection Procedure 84750

BRP FHSAR Rev. 4 Section 11.5

BRP TS Section 13.1

! BRP Elfluent TS (RETS) and Radiological Environmental

Monitoring Program (REMP) Audit - PT-97-01

(dated 1/20-24/97)

BRP Annual Radioactive Effluent Release Report - 1995

BRP DRAFT Annual Radioactive Effluent Release Report - 1996

NUREG-0660

ANSI N13.1-1969

BRP Procedures:

TR-93/CIP-20 (Rev.13) " Calibration of Stack Monitor Detectors" (3-5-96)

TR-104/CIP-37 (Rev. 2) " Calibration of Liquid Radwaste Effluent Process Monitor"

(1-23-96)

TR-105/CIP-38 (Rev. 2) " Calibration of Circulating Water Discharge Process

Monitor" (1-23-96)

T15-01/CIP-26 (Rev. 5) " Semi-Monthly Source Check of Radwaste to Canal

Process Monitor" (2-21-97)

T30-49/CIP-24 (Rev. 6) " Monthly Source and Response Check of Off Gas

Monitors" (2-21-97)

T30-33A/CIP-19A (Rev.13) " Monthly Source and Response Check of Stack

Monitors" (2-21-97)

T30-50/CIP-25 (Rev. 8) " Monthly Source Check of Circulating Water Discharge

Process Monitor" (2-21-97)

T90-20/CIP-27 (Rev.10) " Radiological Effluent Monitor System Chanoc! Functional

Test" (2-21-97)

TR-53/CIP-18 (Rev. 6) " Calibration of Off-Gas Chambers"

(3-7-96)

Condition Reports:

C-BRP-97-0175, "T90-18, Filter not properly installed"

C-BRP-96-988, "RGEM/SGM Low Flow Condition"

C-BRP-96-1011, "High Range Noble Gas Alert and High Alarms On"

C-BRP-96-146, " Lack of Proper Documentation for Acceptable Surveillance Test

Results"

C-BRP-96-800, "RGEM accident filters not available"

C-BRP-97-0171, "RGEM Skid Loss of Communications Light, Processor Fail LED

Flashing"

C-BRP-97-OOO9, " Canal LPM Alarms"

C-BRP-96-287, " Frozen Canal Liquid Process Monitor Suction Line"

14