ML20197E590

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Insp Rept 50-155/97-13 on 971008-1204.Violations Noted. Major Areas Inspected:Major Aspects of Licensee Decommissioning Activities,Including Facility Mgt & Control, Decommissioning Support & Spent Fuel Safety Controls
ML20197E590
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/17/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197E562 List:
References
50-155-97-13, NUDOCS 9712300038
Download: ML20197E590 (12)
v • d • e


See also: IR 05000155/1997013

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U.S. NUCLEAR REOULATORY COMMISSION

REGION lii

Docket No: 50 155

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Lloonse No: DPR-06

Report No: 50-155/97013(DNMS) ,

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Licensee: ' Consumers Energy Company ,

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. Foollity: Big Rock Point Nuclear Power Plant

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- Lou.t!an: 10209 U.S. 31 North

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Charlevoix, MI 49720 l

Dates:- October 8- December 4,1997 ,

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- Inspectors: R. J. Loomon, Senior Resident inspector

C. E. Brown, Resident inspector

Approved by; Bruce L. Jorgensen, Chief '

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Dooommissioning Branch

DMalon of Nuclear Materials Safety ,

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EXECUTIVE SUMMARY

Big Rock Nuclear Power Plant

RC Inspection Report 50-155/97013

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This routine inspection covered major aspects of licensee decommissioning activities, including

facility rr.anagement and control, decommissioning support, spent fuel safety and radiological

controls.

Eacilityldanagement and control

  • The inspectors identified no concems with the conclusions of the PRC that no

unreviewed safety questions were created in changes to the Final Hazards Summary

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Report and proposed changes to the Technical Specifications. (Sections 1.1 and 1.2)

  • The tect.rlty staff coped well with the increased security challenges caused by the

increased work force and decommissioning actMties, (Section 1.3)

Decommisslotg3upport Activiiles

  • Maintenance and surveillance activities were correctly performed and accurately

documented. (Section ll.1)

\ * The inspectors identified no safety concems with survelllance tests that were deleted

due to Big Rock Point being In the decommissioning phase of plant operetion.

{ (Section 11.3)

  • The inspectors identified no safety concerns with deleted predictive and preventive

activity controls due to Big Rock Point being in the decommissioning phase of plant

operation. (Section ll.4)

SpentfueLSafeti

e The reactor vessel was emptied of core components after an appropriate procedure

change authorized the use of the attemate spent fuei poal(SFP) channel handling tool

for removal of a bowed channel. (Section 111.2) ,

  • Operators and reactor engineers had limited guidance and lacked a questioning attitude

conceming the weight of items hanging on SFP rail spans, and the weight of items being

added to the rail 4 pans by the operators. SFP rail span No.19 was found with

components hanging from it with a total weight in excess of the 350 pound procedural

limit. (Section 111.3)

fladiologicaLControls

  • Health Physics technicians gave good radiation work permit (RWP) and as low as

reasonably achievable (Al. ARA) pre-job briefings. (Section IV.1)

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e Soll excaveted to remediate a diesel fuel oil sp(h was properly sampled and stored.

(Section IV.2)

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Repori_ Details

Summary _of Plant Status

The lic1nsee began the inspection period with the plant in the decommissioning phase of plant

life. All fuel bundles were stored in the spent fuel pool (SFP). On November 10,1997, the last

fuel channel was remnved from the reactor and on December 2,1997, the reactor vessel head

was re-installed. The removal of fuel channels and control rod blades from the reactor core

were performed in preparation for the primary system decontamination flush.

As of November 25,1997, the SFP lodine inventory, after more tha,i ten half lives of lodine 131

decay, would cause a member of the public at the closest site boundary, to receive 1.0 rem

committed dose equivalent (CDE) to the thyroid. The total effective dose equivalent (TEDE) to

the total body would be less than 0.1 rem. In comparison,10 CFR Part 100 limits are 300 rem

CDE to the thyroid and 25 rem TED5 to the total body. The Environmental Protection Agency's

(EPA's) Protective Action Guides are 5 rem CDE to the thyroid and 1 rem TEDE to the total

body. Big Rock Point passed the time at which 10 CFR Pert 100 limits could be exceeded on

September 19,1997,20 days post shutdown. Big Rock Point passed the time at which the

EPA's Protective Action Guides could be exceeded on November 6,1997,68 days post-

shutdown. This data is the licensee's basis for proposed Technical Specification (TS) changes,

LEacility_ Management.And.CQulfD)

1.1 PJaniReview comml11ec.(P.RCRicelings

The inspectors attended PRC meetings and verified that a quorum was present. The

inspectors also evaluated ongoing discussions and the bases for the determination that

the proposed changes were not unreviewed safety cuestions. The following items were

discussed:

  • Changes tu Final Hazards Summary Report (FHSR), Chapter 15, " Accident

Analysis " Chapter 15 was re'.vritten to delete those accidents which have no

possib:lity of occurring with the reactor permanently defueled. Accidents which

have a potential to occur during decommissioning were incorporated into

C:', apter 15.

  • Change requests to TS, Section 0, " Administrative Controls," were approved to

allow changing the required staffing and operator license requirements.

The inspectors identified no concoms with the PRC conciusions,

l.2 Post ShutdowrtDecommissioning.AcitvlifesReportESDAR

The inspectors reviewed the updated PSDAR to remain cognizant of plans and

schedules. The NRC conducted a public meeting on November 13,1997, where the

changes to the PSDAR were discussed. The inspectors attended this meeting. The

details of the meeting will be documented by the NRC Office of Nuclear Reactor

Regu% tion.

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1.3 Increase 1 Security Woiload

Observations were routinely conducted in tha areas of security and safeguard activities

using inspection Procedure 71750. The inspectors observed increases in the number of

plant staff entering and working in the protected area and in the quantity of supplies

entering the protected area. The incr9ased number of workers in the protected area

resulted in an increase in the number of logable security and security conditbn reports

generated. The immediate corrective actions to these reports appeared appropriate.

The inspectors also noted an increase in plant vehicle traffic. The security force coped

well with this increated work load.

ILDecorntnissioningEuppsiActivillas

11. 1 Observation of Actlylties

Numerous work activities and tests were observed and/or reviewed to verify they were

conducted safely and in accordance with appropriate procedural controls,

n. Inspacilon_ScopM62ZD3).IE1226)

The inspectors observed all or portions of the following work activities:

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MalatenanceActivillas

  • WO 12710979: Installing ventilation ductw d for HEPA filter

e WO 12711095: testing standby dieset bre Aker

  • WO 12710938: set and tension reactor head

Sutyelllance Activities

  • W P.1: standby diesel generator start and run test
  • TV 26: !acalleak rate testing
  • TV 59: fuel pool heatup test
  • T180-01A: containment ventilation valves leak rate test

b. Observations and Findings

The maintenance and surveillance activitiet, observed were property conducted in

accordsnee with applicable procedures. The inspectors did not observe any decrease in

performance nor any imprmer work. Surveillance postponement due to the final plant

shutdown did not occur. Pre-job briefings attended by the inspectors were well

conducted,

c. Conclusions

Maintonance and surveillance activities were correctly performed and accurately

documented,

SpontEuct Pool Heatun Rate Test

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11. 2

On Nwomber 22,1997, the operators performed SFP heatup tast TV 59. This test was

conducted to confirm that the heatup curves based on 1.4'F/HR were accurate. The

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16consee fic-;-::d chan'A4 To the TS based on the SFP taking greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to

heat the pool by 70'F. 'cs 60'F to 150'F. All cooling was shut off to the SFP for 10

hours. The initial pool ww erature was 62'F, and the final SFP temperature was 68'F,

. yield 6ng a hostup rate of v.S'F/HR. This test showed tht it would now take at least 116

hours for the SFP to heat up by 70'f' with loss of oooling to the pool. Based on TV-59,

' the inspedor conclJded that the SFP heating graphs were conservative, and that the

reactor engineer's assessment of ths SFP heat load was conservative. Also, the heat

load to the SFP was within the assuicntion for the proposed TS for a defueled plant.

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11.3 Deleted Surveillance Tanis

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a. Inapadion haam

As a consequence of permanent shutdown of the reactor, some periodically scheduled <

surveillance tests became unnecessary or inappropriate. The inspectors reviewed the  ;

process which deleted the surveillance tests listed below.

b. Obaarvations and Findings

lhe licensee evaluated surveillances to determine which were not required to be j

performou during the decommissioning phase of plant operation. The applicable plant

procedure required a safety evaluation and having the procedure being deleted undergo

review by the Plant Safety Review Committee (PRC). The following surveillances were

deleted by this process:

o T7-12 Pipe Tunnelinspection

e T718 Bypass Valve Test

e T7-30 Plant Water inventory

  • ' T7-33 Check of Auxiliary Shutdown (ASD) System Equipment

e T30-01 - Monthly RPS Logic Test

  • T30-03 CRD Selector Valve Reduced Pressure Test
  • T30-05 CRD Position Motor Generator Test

e T30-33 Check of ASD System Equipment Checks

c. Conclualon

The inspectors identified no safety concems with surveillance tests that were deleted

. due to Big Rock Point being in the decommissioning phase of plant operation.

ll.4 Deleted Pranctive and Preventive Activitv Controla (PPACA) -

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aJ inanadan Scope

The inspectors held discussions with the Predictive and Preventive Activity Control

(PPAC) coordinator and reviewed the list of PPACs deleted as unnecessary or

. inappropriate considering permanent reactor shutdown.

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b. Obrarvatbnn and findings

A maintenance review comm!ttee met and determined which PPACs had no continuing

regulatory basis in the TS, final hazards summary report (FHSR), insurance, or other

commitments. The deleted PPACs were determined to have no efioct on needed

equipment in the decommissioning mode of operation. Approximately 2,600 PPACs

were reviewed; of those,316 were deleted.

c. Conclusion

The inspectors identified no safety concerns with deleted PPACs due to Big Rock Point

being in the decommissioning phaso of plant operation .

IILSpantfuaLSafety

111. 1 General

The inspectors conducted frequent reviews of ongoing decommissioning activities,

focusing on spent fuel safety. Specifit., events and findings are detailed in the sections

below.

111. 2 Emptying the Reactor of Fuelfhannels and Control Rod Blades

a. Insnection Scope

The inspectors reviewed SOP-44, " Spent Fuel Pool Operations and New Fuel," and

SOP-02, " Refueling Operation," and observed operators perform activities that emptied

the reactor vessel of 88 fuel channels and 32 control rod blades in preparation for the

full primary system dscontamination flush.

b. ObseIYahons and Findings

Pre-job briefs were thorough and contained good Interaction among crew members.

The movement of channe.ls and blades was performed within the guidance of

SOP-02. One channel was too bowed to allow for the use of the normal channel

handling tool, as the tool guide balls would not fit into the channel. Work was stopped

and changes to SOP-02 were made and approved to allow for the use of the SFP

channel handling tool which had no guide balls. On Novernber 10,1997, the channel

was removed from the reactor vessel and placed in the SFP, emptying the reactor

vessel of core components.

c. Conclusion

The reactor vec 'el was carefully and effectively emptied of core components. An

appropriate procedure change was implemented to allow use of the alternate SFP

channel handling toolin successful removal o a bowed channel.

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Ill.3 SpanEuelEcoLRail Soan N119 Weight Limit Exceeded i

a. Inrtpaction. Scope

On October 9,1997, the inspectors observed that operators wvre hanging core ,

components on spans of the spent fuel pool (SFP) rails. System Operating Procedure l

(SOP)-44, * Spent Fuel Pool Operations and New Fuel Handling," was examined, and

the inspectors questioned plant staff as to the weight of the items already hanging on

the SFP rail spans and the weight of the items being added by the operators. l

b. Obser.vations and Findings

On October 9,1997, the inspectors raised questions with various plant staff as to the

weight of core components which were being hung from the spans of the SFP rails, and

the weight of the components that were already hanging oi, the rail spans. The licensee

did not know or have records as to the weight that was already hanging from the rail

spans. Changes were mad 9 to the applicable procedure, SOP-44 " Spent Fuel Pool

Operators and New Fuel Handling," and items hanging from certain SFP rail spans were

weighed and the weights recorded. On October 29,1997, the operators discovered that

SFP rail span No.19 had core components hangirig from it with a total weight of 497

pounds, exceeding the weight limit of 350 pounds in SOP-44 by 147 pounds. In that

implementation of SOP-44 is a requirement of TS 6.8.1 by reference through the

licensee's Quality Program, exceeding the noted limitation of SOP-44 is considered a

violation (50-155/97013-01(DNMS)).

The licensee lacked records showing weights and dates for placement of components in

suspension off the SFP rails. Therefore, the length of time the welght limit was

exceeded could not be determhed.

After if was discovered that SFP rail span No.19 was weighted beyond procedure limits,

the operators moved some items to other rail spans. The total weight left on SFP rail

span No.19 was 329 pounds. The weight of items on other rail spans were checked

and found to be less than 350 pounds. Condition Report (CR)

C-BRP-97 534," Exceeding 350 pounds on Spent Fuel Pool Rail Spans * was written by

the shift supervisor, immediate corrective cetions were as follows: 1) no additional

material may be hung on rail spans 18,19, and 20; 2) before adding any additional

material on other rail spans, it must be verified that the additional load will not cause the

total weight on the rail span to exceed 350 pounds; 3) SOP-44 was revised to include a

section for weighing items; and 4) the reactor engineer provided the operators with

written instructions containing weights of core components remaining to be removed,

and identifying the rail span on which to hang each component. On November 10,

1997, the last core components were removed from the core. The inspector verified the

components were distributed on the SFP rail spans to ensure that the total weight on

any rail span did not cxceed 350 pounds.

The inspectors found that the safety significance of the excess 147 pounds

hanging on SFP rail span No.19 had not been evaluated by the engineers. When the

inspectors questioned this, the licensee stated that the engineers will provide the

inspectors w;th an evaluation. This is an inspector follow-up item

(50-155/97013-02(DNMS)).

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c. Condualon

Operators and reactor engineers had limited guidance and lacked a questioning attitude

conceming the weight of items hanging on the SFP rail spans. The weights of items

being added to the rail spans by the operators were not monitored or controlled. SFP

mil span No.19 was found with core components hanging from it with a total weight in

excess of the 350 pound procedurallimit.

Ill.4 Idousekeeping

During frequent tot'n of the contalnment and other buildings, the inspectors noted that

trash and debrie ,a starting to accumulate and the geneial cleanliness throughout the

plant was beg' .g to decline. For example, the inspectors noted that bags of

radioactive mt.t .al were accumulating in many areas of the turbine building. The plant

manager was informed of these observations. On subsequent plant tours, the

inspectors rioted that the conditions had improved.

ILRadiologicaLControls

IV.1 General

Using inspection Procedures 71707 and 71750, the inspectors made frequent tours of

the radiologically protected area (RPA) and discussed specific radiological controls with

the ALARA coordinator and various radiation protection (RP) technicians. The

inspectors observed plant conditions and licensee performance, including radiation

protectinn practices, which were satisfectority performed by plant workers during this

inspection period. Radiation protection practices performed by plant workers removing

the reactor core components were good. There wera two minor contaminations of

worker faces. The RP prejob, and radiation work permit (RWP) and ALARA briefings

were conducted with good interactions and inf ormative details provided by the RP

technicians. The inspectors concluded that the implementation of the radiation

protection program during this insp3ction period was good.

IV.2 BadioactMty Eample of Soll after Diesel olLSpill

a. Inspection Scope

The inspectors monitored the chemistry department's activities related to collecting and

sampling the sollin the area of a diesel oil spill. The inspec6rs also reviewed the

immediate corrective actions of CR C-BRP-97-563, * Diesel Oil Splil."

b. Observations _and Findings

On November 19,1997, a backhoe and bucket tractor were parked on the railroad

tracks near the condensate tank. On November 25,1997, at 7:45 a.m., a worker

discovered that the fuel tank had emptied onto the ground. About 25 gallons of diesel

fuel had leaked from the tank. A broken sediment bulb in the fuel line was the cause for

the fuel oil leak. To prevent potential migration of fuel to Lake Michigan, a cleanup was

required; however, the soll potentially contained rr.diological contamination which also

had to be addressed.

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Immediate corrective actions taken by the chemists were to rope off and cover the area

where the oil had leaked. Plant prints showed a 6" perforated pipe buried in the area to

keel the rail-bed dry, so chemists placed an absorbent boom in the drainage ditch. The

chemists then sampled the top soll to determine where on site to store the soll.

As the first stage of environmental cleanup,1.5 cubic yards of soll were remaved and

placed in three 55-gallon drums. The work was then halted until the rails and ties could

be removed for further excavation. Six separate soll samples were taken and analyzed

on the gamma spectroscope analytical system.

Three soll samples identified Co-60 or Cs-137 activity at lavels above background. The

background for Co-60 is considered to be 0.0 uct/gm, and the background for

Cs 137 is 4.2e 7uci/gm. All the samples were below TS limits. The actual results are

shown in the following table, with the background subtracted.

SAMPLE # Co 60 uct/gm Cs 137 uct/gm

2 2.05e 7 2.80e 7

3 1.50e-7 01.8e-7

5 3.28e-6 background

The remaining three samples contained only naturally occurring background peaks with

no identifluition ol plant-origin nuclides.

The inspectors observed that the three drums were properly posted and stored in the

waste hold tank radiation material area. The final disposal of this. soll will be performed

in accordance with existing plant procedures. The sampling of the rest of the sollis an

inspector followup item (50155/97013-03(DNMS)).

c. Conclusion

Soll contaminated from a diesel fuel oil spill was properly sampled to assess potential

radiological content, and was properly stored pending final disposal.

LP_raylously_ identified.lsmuna_(92I00)

V.1 (Closed) LER 50-155/97005: Violation of facility operating license.

Big Rock Point's Operating License, Section B(2)(b), prohibits storage of materials in the

area between spent fuel rack B and the east wall of the SFP, so that local temperatures

in the fuel pool will remain consistent with the cooling analysis of record. Contrary to this

requirement, a 5 Dallon stainless steel bucket was discovered on the SFP floor between

rack B and the east wall of the SFP on October 9,1997. The licensee could t'ot

determine the length of time the bucket was in the pool. Poor lighting in that area of the

pool was a causal factor for not discovering the bucket sooner.

The bucket was removed the same day, and facility procedure SOP-44, " Spent Fuel

Pool Operations and New Fuel" was revised t = e tsure that this area is kept clear. An

engineering safety analysis confirmed that the e was no immediate or past operational

safety concem with the bucket between "B" rack and the east wall of the SFP. The

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conclusion of the evaluation was that there was no significant change in tim heat I

transfer and heat removal capability of the spent fuel pool with the bucket in tte pool.

The inspectors reviewed the engineering evaluation and agreed with the licensee's

conclusion. The inspectors also reviewed the changes to SOP-44 wh:ch require that

material shall not be stored in the area between the *B" Rack and the east wall of the

fuel pool (northeast comer), from the pool floor to the top of the fuel racks. After each

work shift in the SFP this area shall be verified clear and an entry made in the Control

Room Log to document this verification. The inspectors verified by visualinspection that

the area is being maintained clear of objects that could affect heat transfer. In addition,

the inspectors reviewed log entries that documented the area was being inspected by

the operators after work in the SFP and was being maintained clear of objects.

This event had relatively low safety significa,nce, and the licensee's immediate action

taken appeared effective. Therefore, this example of failure to comply with

Section B(2)(b) of the operating license is considered a licensee-identified and corrected

violation. This violation is being treated as a Non Cited Violation, consistent with

Section Vll.a.1 of the NRC Enforcement Policy (50155/97013-04(DNMS)). The

completed corrective actions close LER 50-155/97005, and the inspectors have no -

further concems.

V.2 (Closed)V10 50-155/96010-02: Cold! warm weather checklist sign-off. The cold / warm

weather checklist sign-off (0-VAS 1 Revision 20) was satisfactorily completed on

De,cember 3,1997. The inspectors have no further concems.

VI. Management. Meetings

ExlLMeeting summary

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

conclusion of the inspection on December 4,1997. The licensee acknowledged the findings

presented.

The licensee did not identify any of the documents or processes discussed in this report as

being proprietary.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

K. Powers, General Manager

D. Hice, Plant Manager

K, Pallagl, Chemistry / Health Physics Manager

W. Trubilowicz, Outage / Work Control Manager

G. Withrow, Engineering Manager

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INSPECTION PROCEDURES USED

- IP 37551:- Engineering

1061726: Surveillence Observations

IP 62703: Maintenance Observation

IP 71707: Plant Operations  !

- IP 71750: Plant Support M l

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ITEMS OPENED AND CLOSED )

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Opened

155/9701301 VIO Procedure Violation of SFP Rail Span Weight Limit Exceeded ,

155/9701342 IFl Engineering Evaluation on SFP Rail Span Weight Limit Exooeded l

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155/97013 03 IFl Diesel FuelOil Spill Soil Sampling

165/97013-04 NCV Failure to Comply with Operating Lloense Section B(2)(b)

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155/96010 02 VIO Cold / Warm Weather Checklist Sign off

LER Violation of Facility Operating Lloonse

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155/97005

- 155/97013-03 NCV Failure to Comply with Operating Lloonse Section B(2)(b)

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LIST OF ACRONYMS USED

ALARA As Low As Reasonably Achievable

CFR Code of Federal Regulations

CR Condition Report

FHSR Final Hazards Summary Report

HEPA High Emcient Particulate and Absolute

HP Health Physics

IFl Inspection Followup Item

IR inspection Report

LER Limnsee Event Report

NCV Non-Cited Violation

NOV Notice of Violation

NRC Nuclear Regulatory Commission

PPAC Predictive and Preventive Activity Control

RP Radiation Protection

RPA Radiologically Protected Area

PRC Plant Safety Review Committee

PSDAR Post Shutdown Decommissioning Activities Report

RWP Radiation Work Permit

SFP Spent Fuel Pool

SS Shift Supervisor

> TS Technical Specification

VIO Violation

WO Work Order

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