ML20214L937
| 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) | |
See also: IR 05000155/1986013
Text
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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
% A /ltsto w (I
Y27/44
as
Inspector:
A. G. Januska
p
Q 9] / /l 4.e.*: d v
Approved By:
M. C. Schumacher, Chief
- M7/M,
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.
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8609100460 860827 '.
ADOCK 05000155
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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
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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
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
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.
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
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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
T
L WASTE
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
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
1.6E-03
6.2E-05
1.8E-03
5.0E-05
1.1E 00
2.6E 01
A
bFTl
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
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
2.3E-05
1.6E-06
2.0E-05
1.1E-06
8.9E-01
1.4E 01
A
g g_.y
1.1E-04
2.6E-06
1.1E-04
2.6E-06
1.0E 00
4.1E 01
A
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
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
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
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
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
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
1.9E-04
4.2E-05
1.6E-04
2.7E-05
8.6E-01
4.5E 00
A
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
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
2.3E-05
1.6E-06
2.3E-05
9.5E-07
9.8E-01
1.4E 01
A
DET8
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
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
2.0
2.4 and
<8
0.5
-
1.67
.2E and
<16
0.6
-
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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