ML20214L937

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Insp Rept 50-155/86-13 on 860804-08.No Violations or Deviations Noted.Major Areas Inspected:Confirmatory Measurements Program & Implementation of Radiological Environ Monitoring Program
ML20214L937
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 08/27/1986
From: Januska J, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214L929 List:
References
50-155-86-13, NUDOCS 8609100460
Download: ML20214L937 (8)
v • d • e


See also: IR 05000155/1986013

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/86013(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: August 4 through 8, 1986

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Inspector: A. G. Januska p Y27/44

Q 9] / /l 4.e.*: d v

M. C. Schumacher, Chief #M7/M,

Approved By:

Radiological Effluents and Date

Chemistry Section

Inspection Summary:

Inspection on August 4 through 8, 1986 (Report No. 50-155/86013(DRSS))

Areas Inspected: Routine unannounced inspection of (1) the Confirmatory

Measurements Program including sample split and onsite analysis with the

Region III Mobile Laboratory; review of the licensee's counting room quality

control program, (2) the implementation of the Radiological Environmental

Monitoring Program and (3) an open item identified during a previous

inspection.

Results: No violations or deviations were identified. .

8609100460 860827 '.

PDR ADOCK 05000155

G PDR-

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DETAILS

1. Persons Contacted

  • D. Hoffman, Plant Superintendent
  • L. Monshor, QA Superintendent
  • R. Alexander, Technical Engineer
  • J. Beer, Chemistry and Health Physics Superintendent
  • R. Garrett, Health Physics Supervisor
  • R. Bearss, Senior Chemistry and Health Physics Technician

J. Plunkett, Senior Chemistry and Health Physics Technician

J. Heinlein, Chemistry and Health Physics Technician

  • S. Guthrie, NRC Senior Resident Inspector
  • Denotes those present at the exit meeting.

2. Licensee Action on Previous Inspection Findings

(Closed) Open Item (155/84006-02): Recalibrate charcoal geometries by

September 1, 1984. This item remained open after inspection 50-155/85017

comparisons resulted in disagreements for this geometry. Although the

licensee had recalibrated, the disagreements were due to differences in

activity distribution between the actual sample and the calibration

standard.

The licensee again recalibrated the charcoal geometry after investigating

various analytical techniques which would assure reliable results. The

calibration was verified to be accurate based on examination of data and

the comparison results, in which all agreements on both detectors 1 and

2, listed in Table 1 were obtained.

3. Environmental Protection

The inspector examined the 1984 and 1985 annual Radiological Environment

Monitoring Report which contained the licensee's voluntary program of

particulate and radiciodine air sampling, lake and well water, aquatic

biota and sediment, milk, and the single Technical Specifications (T/S)

requirement of film or TLD monitoring. No unusual trends appeared to be

attributable to plant opp ations.

The inspector reviewed the new Radiological Environmental Monitoring l

l Program (REMP) which was required to be implemented effective January 1, '

1986, and the licensee's Environmental Contractor's monthly results for

January through May 1986 to assure compliance with the program. The

inspector pointed out differences between the old and new program

descriptions, typically used in the annual report, and stressed that

(1) an accurate version be used and that (2) T/S 6.9.2.1 and T/S 13.2.3

be consulted for the details required in the annual report and the Offsite

Dose Calculation Manual (0DCM).

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The report of audit QT-85-22 "BRP and PAL Radiological Environmental

Monitoring Program and Radiological Effluent Technical Specifications"

conducted November 12-15 and December 2-3, 1985 was reviewed. Observations

made in the audit report dealt with administrative requirements of the REMP

and the effluent technical specifications. No findings were from BRP.

The inspector discussed the new audit requirements for the REMP. The

licensee's Environmental Sample Log, which contains a Monthly Collection

Checklist, vacuum gauge calibration data and collection sheets for the

various groups of samples, was examined. The log appeared to be complete

and up-to-date.

No violations or deviations were identified.

4. Confirmatory Measurements

a. Sample Split

Fire samples (air particulate, charcoal, liquid waste receiver tank,

gas and reactor coolant) were analyzed for gamma emitting isotopes

by the licensee and in the Region III mobile laboratory onsite. All

samples were analyzed on both detectors 1 and 2 except for the gas

and reactor coolant samples which were only analyzed on detector 1.

Results of the sample comparisons are listed in Table 1; comparison

criteria are given in Attachment 1. The licensee achieved a total

of 50 agreements out of 51 comparisons.

The lone disagreement, Xe-133 in the gas sample, was examined as

were the results of the other nuclides and the gas results obtained

during the inspection conducted in September 1985. The comparison

for Xe-133 in 1985 was also technically a disagreement but the

criterion was relaxed to compensate for nonuniform thickness between

the bottoms of glass sample vials which produces different

attenuation of tle 81 key energy line. However, further examination

of the 1986 ref ults indicated that except for Kr-88 the results are

conservatively biased and the ratios of the licensee's results to

the NRC results increase with decreasing energy. This relationship

and the fact that the gas geometry was calibrated with a liquid

containing mixed radionuclides indicates that the bias is caused

by a lack of self absorption corrections for the various energies.

The licensee agreed to determine a suitable standard to be purchased

and calibrate gas geometries within two weeks after the receipt of

the standard, bearing in the mind the possible need for self

absorption correction (0 pen Item 155/86013-01).

A dirty waste receiver tank (DWRT) was sampled and split to test

the licensee's liquid release geometry. The initial sample, counted

before dilution and filtration, indicated the presence of Sn-113 in

both the licensee and NRC portion; however, this nuclide was not

present in the licensee's liquid library and therefore was not

identified or quantified. Although this nuclide was not present in

the sample when filtered (see L WASTE on Table 1) which is more

representative of a release sample, the licensee agreed to add it

to appropriate libraries and job streams (0 pen Item 155/86013-02).

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The licensee further volunteered to review his release libraries

for any other missing nuclides. The licensee also agreed to

analyze a portion of the DWRT for gross beta, H-3, Sr-89, and

Sr-90 and report the results to Region III (0 pen Item 155/86013-03).

The inspector examined Chem tank and DWRT batch release data from

January 15 through July 19, 1986, which includes gamma spectrographic

analyses, for the presence of Sn-113. No evidence of the presence of

Sn-113 in any release was found.

b. QA/QC of Analytical Measurements

The licensee conducts a proceduralized QC program for a gamma

spectrometer, two gas proportional counters (one currently out

of service) and a well counter in the counting room. Results of

required daily tests are recorded in two log books. Test results

beyond the QC tolerance are circled in red; a second test performed

and supervision informed if appropriate. The inspector reviewed

entries in these log books and found that tests are being performed

as required, entries beyond a tolerance noted and comments of actions

taken logged.

The backup / emergency gamma spectroscopy system (detector 2), used

for the sample split analyses (Section 4a), is located in the air

compressor room in an extremely warm environment. It is normally

left unpowered and is only source tested and energy calibrated

prior to use. The inspector discussed the need for routine testing

of this system and providing a more suitable environment. The licensee

acknowledged the inspector's comments and agreed to perform a monthly

source test on this system and an energy calibration if required

(0 pen Item 155/86013-04).

No violations or deviations were identified.

5. Training

The inspector noted that a Chemistry and Health Physics Teci.nician

(C & HP) on the backshift did not appear to be fluent in the operation

of the backup / emergency gamma spectroscopy system and exhibited lack

of confidence in the manual operation of the main system. It appeared

that his knowledge was limited to operation of this system automatically

via job streams. In discussing this the licensee stated that as part of

initial site laboratory and counting room training, gamma spectroscopy

is presented on-the-job by a qualified technician and is limited primarily

to the operation of the main system. The last structured training on

gamma spectroscopy was presented about one and one half years ago, before

half of the current technicians were employed by the licensee. The

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inspector discussed the benefit of instilling confidence in the

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technician by having them become familiar, to a reasonable degree,

with manual operation of this equipment and various sections of the

analytical report the ' system produces. The licensee acknowledged

the inspector's comments and agreed to present such training with

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six months (0 pen Item 155/86013-05).

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No violations or deviations were identified.

6. Open Items

Open items are matters which have been discussed with the licensee, which

will be reviewed further by the inspector, and which involve some action

of the part of the NRC or licensee or both. Open Items disclosed during

the inspection are discussed in Sections 4a, 4b, and 5.

7. Exit Interview

The inspector reviewed the scope and findings of the inspection with

licensee representatives listed in Section 1. Accuracy in REMP

definition, implementation and reporting; the need for recalibration

of gas geometries and addition of Sn-113 in release libraries; and

training of technicians were discussed in detail. The licensee

acknowledged the inspector's comments.

During the exit interview, the inspector discussed the likely

informational content of the inspection report with regard to

documents or processes reviewed by the inspector during the inspection.

Licensee representatives did not identify any such documents or processes

as proprietary.

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Attachments:

1. Table 1, Confirmatory Measurements

Program Results, 3rd Quarter 1986

2. Attachment 1, Criteria for Comparing

Analytical Measurements

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TABLE 1 -

U S NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

CONFIRMATORY MEASUREMENTS PROGRAM

FACILITY: BIG ROCK

FOR THE 3.OUARTER OF 1986

,

NRC------- ----LICENSEE-- LICENSEE:NRC----

SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T

L WASTE CS-137 7.1E-05 1.9E-06 6.4E-05 1.5E-06 8.9E-01 3.7E 01 A

C FILTER I-131 5.1E-02 3.2E-04 5.1E-02 3.3E-04 1.0E 00 1.6E 02 A

BET A I-133 1.8E-02 4.3E-04 1.7E-02 3.7E-04 9.7E-01 4.1E 01 A

i BR-82 1.4E-02 3.4E-04 1.4E-02 3.2E-04 1.0E 00 3.9E 01 A

XE-133 2.7E-02 3.7E-04 3.3E-02 3.8E-04 1.2E 00 7.5E 01 A

P FILTER NA-24 1.1E-03 2.1E-04 1.7E-03 1.7E-04 1.5E 00 5.4E 00 A

bFTl I-131 1.6E-03 6.2E-05 1.8E-03 5.0E-05 1.1E 00 2.6E 01 A

I-133 1.3E-03 1.5E-04 1.1E-03 8.2E-05 8.6E-01 8.8E 00 A

CS-134 4.4E-04 4.4E-05 4.5E-04 4.3E-05 1.0E 00 1.0E 01 A

CS-137 4.9E-04 5.8E-05 4.7E-04 4.8E-05 9.4E-01 8.5E 00 A

BA-140 2.7E-03 1.9E-04 2.6E-03 1.4E-04 9.7E-01 1.4E 01 A

L WASTE CR-51 3.9E-05 7.7E-06 3.3E-05 5.5E-06 8.5E-01 5.1E 00 A

g g_.y MN-54 2.3E-05 1.6E-06 2.0E-05 1.1E-06 8.9E-01 1.4E 01 A

CO-60 1.1E-04 2.6E-06 1.1E-04 2.6E-06 1.0E 00 4.1E 01 A

I-131 9.3E-06 1.1E-06 7.1E-06 8.7E-07 7.7E-01 8.8E 00 A

CS-134 3.5E-05 1.3E-06 3.0E-05 1.4E-06 8.4E-01 2.7E 01 A

CS-137 7.1E-05 1.9E-06 6.2E-05 1.7E-06 8.7E-01 3.7E 01 A

P' FILTER I-131 1.6E-03 6.2E-05 1.7E-03 5.9E-05 1.1E 00 2.6E 01 A

. I-133 1.3E-03 1.5E-04 1.4E-03 1.1E-04 1.0E 00 8.8E 00 A

' O

CS-134 4.4E-04 4,4E-05 3.2E-04 4.6E-05 7.4E-01 1.0E 01 A

CS-137 4.9E-04 5.8E-05 4.6E-04 4.7E-05 9.2E-01 8.5E 00 A

BA-140 2.7E-03 1.9E-04 2.7E-03 1.6E-04 1.0E 00 1.4E 01 A

T TEST RESULTS: I

A= AGREEMENT

D= DISAGREEMENT

  • = CRITERIA RELAXED

N=NO COMPARISON

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TABLE 1

U S NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

CONFIRMATORY MEASUREMENTS PROGRAM

FACILITY: BIG ROCK

FOR THE 3 QUARTER OF 1986

NRC=- - -

LICENSEE---- LICENSEE:NRC---

SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T

i

OFF GAS KR-85M 1.5E-02 1.9E-04 1.9E-02 2.3E-04 1.2E 00 8.0E 01 A

KR-87 5.1E-02 6.0E-04 5.5E-02 6.5E-04 1.1E 00 8.5E 01 A

KR-88 4.7E-02 4.8E-04 4.5E-02 6.5E-04 9.5E-01 9.7E 01 A

XE-133 2.3E-02 2.7E-04 2.8E-02 4.2E-04 1.2E 00 8.3E 01 D

XE-135 7.1E-02 2.7E-04 8.3E-02 3.7E-04 1.2E 00 2.6E 02 A

XE-135M 1.9E-01 5.5E-03 2.0E-01 4.8E-03 1.0E 00 3.5E 01 A

XE-138 3.8E-01 1.5E-02 4.5E-01 1.8E-02 1.2E 00 2.5E 01 A

PRIMARY NA-24 1.6E-03 7.4E-05 1.9E-03 5.1E-05 1.2E 00 2.2E 01 A

CR-51 3.0E-03 2.9E-04 2.8E-03 2.0E-04 9.5E-01 1.0E 01 A

CO-60 1.9E-04 4.2E-05 1.6E-04 2.7E-05 8.6E-01 4.5E 00 A

I-131 1.1E-03 6.1E-05 1.2E-03 3.1E-05 1.0E 00 1.9E 01 A

I-132 6.0E-03 1.3E-04 7.1E-03 9.8E-05 1.2E 00 4.5E 01 A

I-133 3.4E-03 6.3E-05 4.1E-03 4.8E-05 1.2E 00 5.4E 01 A

I-134 1.5E-02 5.6E-04 1.7E-02 5.4E-04 1.1E 00 2.7E 01 A

I-135 6.3E-03 2.4E-04 7.1E-03 2.0E-04 1.1E 00 2.7E 01 A

SR-91 1.6E-03 2.1E-04 1.8E-03 1.2E-04 1.1E 00 7.4E 00 A

SR-92 - 3. 9E-03 1.3E-04 4.8E-03 1.!E-04 1.2E 00 2.9E 01 A

BA-139 6.1E-03 5.9E-04 6.1E-03 2.6E-04 1.0E 00 1.0E 01 A

C FILTER I-131 5.1E-02 3.2E-04 5.0E-02 2.8E-04 9.8E-01 1.6E 02 A

benr i I-133 1.8E-02 4.3E-04 1.7E-02 2.9E-04 9.5E-01 4.1E 01 A

BR-82 1.4E-02 3.4E-04 1.3E-02 2.5E-04 9.3E-01 3.9E 01 A

XE-133 2.7E-02 3.7E-04 3.1E-02 2.9E-04 1.1E 00 7.5E 01 A

L UASTE CR-51 3.9E-05 7.7E-06 2.1E-05 4.3E-06 5.4E-01 5.1E 00 A

DET8 MN-54 2.3E-05 1.6E-06 2.3E-05 9.5E-07 9.8E-01 1.4E 01 A

CO-60 1.1E-04 2.6E-06 1.1E-04 2.0E-06 1.1E 00 4.1E 01 ,A

ZN-65 1.5E-05 2.4E-06 9.1E-06 1.8E-06 6.2E-01 6.0E 00 A

I-131 9.3E-06 1.1E-06 9.8E-06 7.5E-07 1.0E 00 8.8E 00 A

SB-122 9.9E-06 1.7E-06 1.0E-05 1 . 0'E - 0 6 1.0E 00 5.9E 00 A

CS-134 3.5E-05 1.3E-06 3.1E-05 9.0E-07 8.7E-01 2.7E 01 A

T TEST RESULTS:

.A= AGREEMENT

D= DISAGREEMENT

  • = CRITERIA RELAXED

N=NO COMPARISON

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ATTACHMENT 1

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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_This attachment provides criteria for comparing results of capability tests

and verification measurements. The criteria are based on an empirical

relationship which combines prior experience and the accuracy needs of this

program.

In these criteria, the judgment limits are variable in relation to the com-

parison of the NRC's value to its associated one sigma uncertainty. As that

ratio, referred to in this program as " Resolution", increases, the acceptability

of a licensee's measurement should be more selective. Conversely, poorer

agreement should be considered acceptable as the resolution decreases. The

values in the ratio criteria may be rounded to fewer significant figures to

maintain statistical consistency with the number of significant figures reported

by the NRC Reference Laboratory, unless such rounding will result in a narrowed

category of acceptance.

RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE

Agreement

<3 No Comparison

.g3 and <4 0.4 - 2.5

2.4 and <8 0.5 -

2.0

.2E and <16 0.6 -

1.67

jt16 and <51 0.75 - 1.33

251 and <200 0.80 - 1.25

.1200 0.85 - 1.18

Some discrepancies may result from the use of different equipment, techniques,

and for some specific nuclides. These may be factored into the acceptance

criteria and identified on the data sheet.

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