IR 05000155/1986013: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
Line 1: Line 1:
{{Adams
{{Adams
| number = ML20154N455
| number = ML20214L937
| issue date = 09/22/1988
| issue date = 08/27/1986
| title = Fowards Insp Rept 50-155/86-13 on 860915-19 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $187,500 & Generic Ltr 88-07
| title = 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
| author name = Davis A
| author name = Januska J, Schumacher M
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name = Hoffman D
| addressee name =  
| addressee affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.),
| addressee affiliation =  
| docket = 05000155, 05000348, 05000364
| docket = 05000155
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = CIVP-A-091, CIVP-A-91, EA-87-080, EA-87-80, GL-88-07, GL-88-7, NUDOCS 8809290311
| document report number = 50-155-86-13, NUDOCS 8609100460
| package number = ML20154N458
| package number = ML20214L929
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 4
| page count = 8
}}
}}


Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:*  '
{{#Wiki_filter:,-
. . -
      'lkLDfDd.C ('tiO Sh
'
  , ,
ZE/Y I
*
  .
i September 22, 1988  ;
Docket No. 50-155 License No. DPR-06 EA 87-80 Consumers Power Company ATTN: David P. Hoffman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, Michigan 49201 Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT N0. 50-165/86013(DRS))
This r:;fers to the NRC inspection conducted on September 15-19, 1986, at the Big Rock Point Nuclear Plant of activities authorized by NRC License No. DPR-0 The inspection was conducted by a special environmental qualification (EQ)
inspection team to assess the program implemented at the Big Rock Point Nuclear Plant to meet the EQ requirements of 10 CFR 50.49. As a r7sult of the September 15-19, 1986 inspection, a violation of NRC regulatory requirements was identified. NRC concerns relative to this violation were discussed during Enforcement Conferences that were held on July 7, 1987 and July 21, 198 The violation described in the ent.losed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved examples of failures to comply with the requirements of 10 CFR 50.49. The first example involved a Limitorque Motor Actuator that was removed from service after 13 years of operation and was then subjected to a loss of coolant accident (LOCA) test on April 23, 197 The actuator was reinstalled and returned to service. It continued to be used following the November 30, 1985 deadline for environmental qualification of equipment important to safety without being qual 1fied by testing and/or analysis to evaluate aging as well as potential degradation due to the LOCA test. The second example involved the use of environmentally unqualified butyl rubber and polyethylene insulated cables in Class 1E systems including the Main Steam Isolation Valve, the Core Spray System, the Containment Spray System, and the Reactor Depressurization Syste The NRC staff believes that Consumers Power Company (CPCo) clearly should have known about the EQ deficiencies described above. For Limitorque Actuator MO-7068, it should have been clear that the actuator was unqualified because the maintenance documentation provided by Limitorque following the 1975 LOCA testing of the valve actuator did not provide evidence that any refurbishment of the degradable materials had been accomplished or any evidence that such h92gCKc5000155 li eso9pp G
PNu t . _ _ _ _ .__ . -
    . ___ . . _ _ - . .
4 , ,
  .
  .
  .
   . ,
.
  * Consumers Power Comany 2 September 22, 1988 i
U.S. NUCLEAR REGULATORY COMMISSION
2      t
 
: refurbishment had been considered and found unnecessar At the Enforcement l Conferences, CPCo took the position that analysis showed qualification of the -
==REGION III==
  ! actuator for 40 years but the NRC staff has concluded that the data used to
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
support that conclusion did not consider the case in which an actuator had already undergone a once-in-a-lifetime LOCA test and CPCo should have recognized that fact.
  % A /ltsto w (Ias 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 inspectio Results: No violations or deviations were identifie .
8609100460 860827 '.
PDR ADOCK 05000155 G  PDR-
 
  - _   _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.. .
DETAILS 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 meetin . 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 standar 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 obtaine . 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 ation 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. be consulted for the details required in the annual report and the Offsite Dose Calculation Manual (0DCM).
 
  - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
 
r-
  . .
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 specification No findings were from BR 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 examine The log appeared to be complete and up-to-dat No violations or deviations were identifie . Confirmatory Measurements 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 onsit All samples were analyzed on both detectors 1 and 2 except for the gas and reactor coolant samples which were only analyzed on detector 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 comparison 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 lin 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 energie 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 quantifie 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).


. With regard to the unqualified cables inside the containment, CPCo was informed l in an NRC Inspection Report dated August 8, 1984 that the NRC staff had concerns l about the qualification of the cables and that report stated that those concerns !
-
could be addressed by testing the installed cable or by showing qualification
  . .
;
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).
  '
through testing already completed. CPCo decided to show qualification of the j cables by demonstrating similarity of the installed cables to cables already i i tested. It is the NRC staff's position that CPCo clearly should have known that ;
the similarity analysis that was performed by CPCo for the polyethylene  !
) insulated cable as well as the one it performed for the butyl rubber insulated I cable were deficient. In the case of the polyethylene insulated cable, the !
insulation formulation (which includes material, manufacturing process and i j
fabrication) was not shown to be similar to that of the tested cable. In the i i case of the butyl rubber insulated cable, the insulation formulation differed !


from that of the cable cited in the test report relied on by CPCo and the test !
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 foun 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 logge 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 environmen It is normally left unpowered and is only source tested and energy calibrated prior to us 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).
{ conditions used in the cited test report were unstated and therefore could not !
j be shown to be equivalent to the conditions that the installed cable would be subjected to in a LOC [
j
      !
>
To emphasize the importance of (1) management attention to, and control of, the l 3 EQ program, and (2) aggressive management action to ensure that problems are !
I promptly identified and corrected, I have been authorized, after consultation 1 l with the Director, Office of Enforcement and the Deputy Executive Director for Regional Operations, tc issue the Notice of Violation and Proposed Imposition {
      ,
, of Civil Penalty (Enclosure 1) in the amount of One Hundred and Eighty-Seven l J Thousand Five Hundred Dollars ($187,500) for the violation described in the [
]
enclosed Notice. In accordance with the "Modified Enforcement Policy Relating t i to 10 CFR 50.49," contained in Generic Letter 88-07 (Enclosure 2), the violation !
i described in the enclosed Notice has been determined to be moderate and to l have affected some systems and components, and therefore is considered to be !
an EQ Category B violation. The base value of a Civil Penalty for an EQ  :
Category B violation is $150,000.


!
No violations or deviations were identifie . Training
l j In determining the civil penalty amount, the NRC considered the four factors j set forth in the "Modified Enforcement Policy Relating to 10 CFR 50.49," for ;
; 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
! escalation and mitigation of the base civil penalty amount. These factors i consist of (1) identification and prompt reporting of the EQ deficiencies l 3 (150%); (2) best efforts to complete EQ within the deadline (150%);  j
,
! (3) corrective actions to result in full compliance (150%), and (4) duration l l of a violation which is significantly below 100 days (-50%),  i l
inspector discussed the benefit of instilling confidence in the l
With rr N ' to the first factor, no escalation or mitigation is warranted f since a. g W ral issues regarding qualification of cable were clearly  !
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
recogi i by 'he NRC staff and CPCo well prior to the November 30, 1985 l      {
!
i
!      :
i
,
,
l
six months (0 pen Item 155/86013-05).
      :


  -- -  -- ._ - - _-
!
I      ,
* * *
l , .
:
.
  ' '
!       i Consumers Power Company  3  September 22, 1988
      !
.
      !
;
deadline and a violation occurred in this case because CPCo failed to take !
adaquate corrective action. With respect to the second factor, 25 percent !
y mitigation is warranted because best efforts were applied by the licensee to i
: complete EQ within the deadline. However, full mitigation for those efforts is l not appropriate because, notwithstanding the NRC staff's continued concerns ;
j with an issue as fundamental as cable qualification, CPCo did not satisfactorily l j resolve the issue prior to the deadlin With respect to the third factor, j
! 50 percent escalation is war.' anted since the licensee's efforts to make an !
*
operability or qualification determination were not timely and the quality of i i the supporting analyses were unacceptabl With respect to the fourth factor, (
j mitigation is inappropriate since the EQ violation existed in excess of 100 day ;
After reviewing these factors, the base civil penalty has been increased by ,
' 25 percen ;
You are required to respond to this letter and should follow the instructions L
      '
. specified in the enclosed Notice when preparing your response. In your i response, you should document the specific actions taken and any additional l actions you plan to prevent recurrence. After reviewing your response to this
<
Notice, including your proposed corrective actions and the results of future !
inspections, the NRC will determine whether further NRC enforcement action is >
; necessary to ensure compliance with NRC regulatory requirement :
      *


j In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, '
_ . .
i Title 10, Code of Federal Regulations, a copy of this letter and its enclosures l
No violations or deviations were identifie . 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 . 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 detai The licensee acknowledged the inspector's comment 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 inspectio Licensee representatives did not identify any such documents or processes as proprietary.
) will be placed in the NRC Public Document Roo l The responses directed by this letter and the enclosed Notice are not subject j to the clearance procedures of the Office of Management and Budget as required j by the Paper.<ork Reduction Act of 1980, PL 96-51 I I


Sincerely, g
OricinM ei- .d t'/  !
A Bert Davis  !
!    A. Bert Davis  '
j    Regional Administrator J
"
Enclosures:      ! Notice of Violation and Proposed    i 1  Imposition of Civil Penalty    I l Generic Letter 88-07    l I Inspection Report l
<
No. 50-155/86013(DRS)    -
1      l
! See Attached Distribution    !
j g
RIII a/ r 1 [db Gg RIII b;Q$
Schgtz RIII O Papert lg !
j IQ  OE W OGC [g OE:D (97 DEORO (py
,
a is  Luehman Chandler Lieberman Taylor
'
'
y 9-1-0 9-2M 9-s48 3+p
Attachments: Table 1, Confirmatory Measurements Program Results, 3rd Quarter 1986 Attachment 1, Criteria for Comparing Analytical Measurements
      ,
    ,
l    5
  .-.
  .- - -
 
.
. .
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 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
    .
, r.y,,mr-- n,- , , . . , . . -- ~ --
    ,, , - - - . y- - - - - , -
        ,m
 
. ~
l l
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
        .
I
  .. -  - - - _ _ ._ . _ ,


          -
. - _ _ _ - _ , ,
4* 4
  ,
  .
.
  .. .
  ' Consumers Power Company 4    September 22, 1988 Distribution cc w/ enclosures:
Mr. Kenneth W. Berry, Director Nuclear Licensing Thomas W. E1 ward, Plant Manager    '
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Michigan Department of Public Health PDR LPOR SECY l
CA OGPA g 0CO/DCB (RIOS)        .
J. M. Taylor, OEDRO      l J. Lieberman, OE L. Chandler, OGC T. Murley, NRR J. Luehman, OE RAO: RIII PAO:RIII SLO:RIII M. Stahulak, RIII Enforcement Coordinators, RI, RII, RIV, and RV E. Jordan AE00 B. Hayes 01 S. Connelly, OIA OE File EA File
    .
o
  -
  -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - - _ - - - - -
.. ..
ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS
      .
_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 progra 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 acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement
  <3  No Comparison
.g3 and <4  0.4 - .4 and <8 .0
.2E and <16 .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 shee . - _ . ___
    -
}}
}}

Revision as of 04:52, 19 January 2021

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


Text

,-

.

.

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 (Ias 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 inspectio Results: No violations or deviations were identifie .

8609100460 860827 '.

PDR ADOCK 05000155 G PDR-

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.. .

DETAILS 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 meetin . 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 standar 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 obtaine . 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 ation 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. be consulted for the details required in the annual report and the Offsite Dose Calculation Manual (0DCM).

- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

r-

. .

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 specification No findings were from BR 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 examine The log appeared to be complete and up-to-dat No violations or deviations were identifie . Confirmatory Measurements 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 onsit All samples were analyzed on both detectors 1 and 2 except for the gas and reactor coolant samples which were only analyzed on detector 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 comparison 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 lin 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 energie 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 quantifie 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).

-

. .

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 foun 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 logge 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 environmen It is normally left unpowered and is only source tested and energy calibrated prior to us 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 identifie . 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 l

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).

!

_ . .

No violations or deviations were identifie . 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 . 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 detai The licensee acknowledged the inspector's comment 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 inspectio Licensee representatives did not identify any such documents or processes as proprietary.

'

Attachments: Table 1, Confirmatory Measurements Program Results, 3rd Quarter 1986 Attachment 1, Criteria for Comparing Analytical Measurements

,

l 5

.-.

.- - -

.

. .

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 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

.

, r.y,,mr-- n,- , , . . , . . -- ~ --

,, , - - - . y- - - - - , -

,m

. ~

l l

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

.

I

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

-

.. ..

ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

.

_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 progra 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 acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

<3 No Comparison

.g3 and <4 0.4 - .4 and <8 .0

.2E and <16 .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 shee . - _ . ___

-

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000155/1986013&oldid=3089401"