IR 05000155/1988014

Insp Rept 50-155/88-14 on 880620-24.No Violations or Deviations Noted.Major Areas Inspected:Organization & Mgt Controls,Outage Planning & Preparation,Facilities & Equipment,Contamination Controls,Alara Program & Audits

ML20151G231
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/19/1988
From:	Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151G220	List: IR 05000155/1988014 ML20151G217
References
50-155-88-14, NUDOCS 8807280213
Download: ML20151G231 (14)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/88014(DRSS)

Docket No. 50-155 License No. OPR-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, Michigan Inspection Conducted: June 20-24, 1988 Inspector: W. J. Slawinski (A/ ,

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7[M/es Oath Approved By: L. Ro rt reger, Chief 7-/9"88 Facilities Radiation Protection Date Section ,

Inspection Summary Inspection on June 20-24, 1988 (Report No. 50-155/88014(DRSSD Areas Inspected: Routine, unannounced inspection of the radwaste management

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program and selected aspects of the radiation protection program durirs a refueling and maintenance cutage. Areas inspected included: organization and management controls (IP 83722); outage planning and preparation (IP 83729);

facilities and equipment (IP 83727); contamination controls (IP 83726,83729);

the ALARA program (IP 83729); audits and appraf sals (IP 83722, 83729); liquid radwaste (IP 84723); solid radwaste (IP 84722) and gaseous radwaste (IP 84724).

Also reviewed were past open items (IP 92701), radiological controls during spent fuel movement, and a recent external / internal contamination incident (IP 92701).

Results: No violations or deviations were identified. One unresolved item resulting from an internal / external contamination event was noted and warrants further licensee evaluation. Overall, the licensee's radiation protection program appears to be generally effective in protecting the health and safety of occupational workers. The licensee's programs for controlling solid radwaste and liquid and gaseous effluents also appear effective. Noble gas release rates were restored to normal in 1987 and are currently significantly 1 less then the previous four cycle l

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UETAILS

, Persor.s Contacted M. Acker, Senior Engineer /ISI Coordinator ,

• R. Alexander, Technical Engineer

+*J. Beer, Chemisty/ Health Physics Superintendent

+* Burdette, Senior Health Physicist

• T. Elward, Plant Manager

• T. Fisher, Senior QA Consultant

• R. Garrett, Chemistry / Health Physics Supervisor

• T. Hancock, Chemistry / Health Physics Engineer L. Monshor, Quality Assurance Superintendent

• J. Werner, ALARA Coordinator and Chemistry / Health Physics Supervisor

• E. Plettner, NRC Senior Resident Inspector The inspector also contacted other licensee perscnnel in the Operations, Quality Assurance and Chemistry / Health Physics Department * Denotes those present at the exit meeting on June 24, 1988.

+ Denotes those contacted by telephone between July 7-19, 198 . General This inspection was conducted to review aspects of the licensee's radiation protection program during a refueling / maintenance outage and to examine the radwaste management program, including organization and management controls, planning and preparation, facilities and equipment, control of radioactive materials and contamination, the ALARA program, audits and appraisals, solid radwaste, and liquid and gaseous radwaste Also reviewed were past open items, radiological controls during fuel movement and a recent external / internal contamination incident. The inspector conducted independent, direct radiation and contamination surveys of selected plant areas using an NRC survey instrument; survey (smear and direct) results were in general agreement with posted licensee data. During plant tours, no significant posting or procedure idherence problems were identified. Housekeeping was adequate. No significant access or contamination control problems were identified; however, soma concerns were noted and are discussed in Section . Licensee Action on previous Inspection Findings (IP 92701)

(Closed) Open Item (155/86009-02): Review revised Radiation Work Permit (RWP) program implementation and effectiveness. The revised RWP program was fully implemented and tested during the recently completed refueling / maintenance outage and appears to have functioned satisfactoril The revised program appears to have strengthened the radiation protection progra The licensee plans to make minor procedural revisions to the program to improve dose tracking capabilities and exposure assignment for specific jobs. This matter is considered close .

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(Closed) Violation (155/87019-04): Unmonitored liquid radwaste releas The corrective actions specified in the licensee's October 1, 1987-response letter were reviewed and their completion partially verifie The corrective actions included necessary procedural changes and enhanced training for cognizant operations staff personnel. The corrective actions were timely and appear adequate to prevent recurrenc (Closed) Open Item (155/88004-03): Review training, alarm setpoints and relevant use, quality control and calibration procedures for the-whole-body frisker units. These matters are discussed in Section-7; no problems were note (Closed) Open Item (155/88004-04): Surface area used to calculate skin dose from hot particles is contrdy to IE Information Notices. The licensee revised their Radiation Safety Plan to require that skin doses from point source contamination be calculated over 1 cm2 of tissu This matter is considered close (Closed) Open Item (155/88004-05): Review licensee actions to improve future ISI preparation and coordination activitie The necessary program improvements were satisfactorily implemented during the recent refueling / maintenance outage. This matter is further discussed in Section . Organization and Management Controls (IP 83722)

The inspector reviewed the licensee's organization and management controls for the radiation protection and ALARA programs including changes in the organizational structuie and staffing, management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesse The overall Chemistry / Health Physics (C/HP) Department organizational structure remains essentially as previously described (Inspection Report No. 50-155/88004). In 1988, the station's permanent C/HP technician staff has been reduced from its full complement of 12 persons to nine due to transfers ard a health related termination. (The station has conducted the routine radiation protection program with 12 technicians for several years.) The permanent technician staff currently consists j of six Senior Technicians, two Technician IIs, and one Technician The station recently extended an offer to an experienced technician to i

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fill one vacancy and is considering a second experienced individual to possibly fill another. The station plans to operate the routine program {

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with ten or possibly eleven permanent technicians and may retain one or !

two experienced contract technicians to cover during 1988 summer vacations. 1 The staff reductions do not significantly degrade the experience level of i the C/HP technician staff; however, it could strain technician availability l; for job coverage during peak work or emergency periods and thereby reduce the overall effectiveness of the radiation protection program. This matter will continue to be reviewed during future inspection The inspector discussed the intent of Generic Letter 82-12 requirements for limiting Rad / Chem staff (including RCTs) nours of work to assure that, to the extent practicable, personnel are not assigned to shift i

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duties while in a fatigued condition that could reduce their men'tal alertness or decision making capability. During the inspection, a copy of an NRR guidance memorandum (dated April 1,1988) concerning

. applicability of Generic Letter 82-12 to radiation protection staff was provided to the license To meet Technical Specification 6. requirements, the licensee has developed and implemented an administrative procedure to limit working hours of plant staff who perform safety-related functions. Procedure (working hour) limitations reflect Generic Letter 82-12 guidelines and apply to health physicists and C/HP technicians. Deviations from procedural limitations require immediate supervisor and plant manager approval. The inspector selectively reviewed C/HP technician working hours for 1988 and discussed Generic Letter 82-12 applicability with the license C/HP staff members seldom exceed generic letter and procedure working hour guidelines; no problems were note No violations or deviations were identifie . Planning and Preparation (IP 83729)

The inspector reviewed the outage planning and preparation performed by the licensee, including additional staffing, increased equipment supplies, and job related health physics consideration For the 1988 refueling / maintenance outage, the station's radiation protection group was augmented with nine contract health physics personnel (all senior technicians) and one clerical aide to assist

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the ALARA Coordinator. Accor61ng to the licensee, six of the nine technicians had previously worked at the station during previous refueling outages. The experience level and high rate of returning technicians is indicative of a reliable contract staff. The' station's former ALARA Coordinator (retired in 1987) filled one contract technician position and also assisted the ALARA Coordinator'for about one vaek prior to outage commencement. Two contract technicians currently remain onsite and may be retained for the summer to cover during vacation Additional, large-sized protective clothing was purchased to prevent clothing shortages which may have existed during previous outages (Inspection Report No. 50-155/87012). Approximately 300 new PCs were purchased and, according to the licensee, were ample to cover outage need No violations or deviations were identifie . Maintaining Occupational Exposures ALARA (IP 83729)

The inspector selectively reviewed the licensee's program for maintaining occupational exposures ALARA, including: ALARA considerations for ISI outage activities; and establishment of goals and objectives, and effectiveness in meeting the _ __ - - _ _ __- _ _

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In January 1988, the station formed an ALARA Committee composed of members from maintenance, I&C, health physics, operations and engineering staffs. The committee began meeting monthly in February 1988 to discuss dose saving methods and job coordination for their respective department In February 1988, nine station personnel consisting of engineers, shift supervisors and the ALARA Coordinator attended the initial station "ALARA Engineering" training course previously described in Inspection Report No. 50-155/87004. The course is tentatively scheduled to be offered two more times in 1988. According to the ALARA Coordinator, the course is beneficial to developing new and improved dose saving technique The inspector discussed improvements to ISI activities that were implemented during the current outage. (ISI planning, preparation and coordination weaknesses were previously described in Inspection Report No. 50-155/88004). For the initial three weeks of the 1988 refueling / maintenance outage, the station's ISI Coordinator monitored and coordinated back shift ISI activities. For previous outages, ISI back-shift work was supervised by Field Maintenance Services (i.e., the licensee's traveling maintenance service group) Shift Supervisors and not directly by station supervisory personnel. For the 1988 refueling outage, an additional FMS crew was used to reduce (distribute) individual worker exposures and ISI skill center training was expanded to address previous problems with weld preparation and use of grinding wheels. Also, scaffolding construction was improved through better planning and use of the ALARA photo library. For the 1988 refueling outage, about 35 person-rem was expended for ISI activities compared to 68 person-rem to complete similar ISI work in 198 Considerable dose savings was realized particularly for recirculation pump room (17 rem savings) and steam drum (8 rem) ISI activitie For 1987, total station exposure was 211 person-rem, slightly exceeding the station's projected total of 20 For 1988 through May, secondary dosimetry shows that about 129 person-rem has been expended, which is less than projected for this point in the year. The station's 1988 dose projection is 190 person-re No violations or deviations were identifie . Facilities and Equipment (IP 83727)

As previously described (Inspection Report No. 50-155/88004),the i licensee purchased two Eberline Model PCM-1B whole-body contamination i monitors and encountered problems establishing their proper operatio ;

Since this time, the licensee purchased a third monitor and, with the l manufacturers assistance, made all three monitors operational. Two l monitors are located at the primary RCA access control point adjacent I to the C/HP technician office and the third is installed at a recently i established (second) control point. The second access control poirt, located near a former stockroom, was established to facilitate egress primarily for maintenance workers. The licensee is considering further extension of the RCA to occupy a portion of the old stockroom are .

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The primary RCA access control point is clearly visible from the C/HP technician office. The secondary access point is not normally visible or manned by C/HP or security personnel;'however, the licensee modified the whole body friskers audible alarm to also sound remotely in the C/HP technician office. Personnel alarming this monitor are instructed to report to the C/HP technician offic Initially, the licensee discovered that some workers alarming the monitor failed to report to the C/HP technician office and were decontaminating themselves; however, according to the licensee, these problems were corrected and have since ceased. The inspector again alerted the licensee to the potential radiological control problems associated with unmanned RCA egress pnint A related potential problem observed during inspector plant tours is described in Section The inspector reviewed records and relevant (recently implemented)

procedures for operation, quality control and calibration of the

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whole-body contamination monitor Calibrations will be performed annually using three different activity (100 cm2 ) colbalt-60 plate sources; weekly operational checks are also performed using one of the cobalt sources. Technetium-99 button sources are used to set optimum operating voltage plateaus. Monitor alarm setpoints are established using a 5000 dpm (2.25 nCi) colbalt-60 plate source; no problems were noted. According to the licensee, the monitors have been operating satisfactorily thus fa No violations or d9viations were identifie . C_ontrol of Radioactive Materials and Contamination (IP 83726, 83729)

The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of methods of control of radioactive and contaminated materials; management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesse Contamination Control Program and Personnel Contamination Events If an individual alarms the PCM-1Bs, a hand-held (pancake probe)

frisk is performed of the suspect contaminated area. The licensee reports all skin contaminations exceeding 100 cpm above background detected using the pancake probe and accumulates the data for ALARA purposes. In 1988, the licensee began recording clothing contaminations using the same criteria. The inspector selectively reviewed Personnel Contamination Reports (PCRs) for 1988 to dat During the 1988 refueling / maintenance outage to data (April 9, 1988 - June 24,1988), 51 skin and 81 clothing contamination incidents were reported; this amounts to a yearly total of 71 skin and 147 clothing event In 1987, a total of 79 skin contamination events were reporte <

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After installation of the whole-body frisker units (March 1988),

the licensee began identifying numerous low-level (primarily shoe)

contaminations which alarm the contamination monitors but cannot be detected usino the hand-held friskers. The licensee estimates that greater than 50% of all individuals leaving the RCA have been alarming the foot monitors. The contamination is usually easily removed using soap and water; however, the licensee has confiscated over 20 pairs of work boots with low-level contamination which could not be adequately decontaminated. The licensee is currently evaluating the possible source (s) of these events and believes the problem could ,

stem from the plant's ventilation system or result from minor steam leaks. It does not aprear that the contamination is caused by discrete events. The inspector discussed the desirability of tracking / trending personnel contamination events, locations, and presumed causes to aid their evaluatio The licensee plans to obtain tecnnical assistance from their corporate office to evaluate the plant's ventilation syste To strengthen the contamination identification and control program,

the licensee intensified their routine survey program by initiating large area masslin smears, devoted additional man-hours (during the outage) to general plant decontamination, and is considering options to improve radiation worker contamination control practices and oversight of radiological work. The licensee's progress in identifying the source (s) and reducing the number of low-level personnel contamination events will be reviewed during future inspections (0 pen Item 155/88014-01). The licensee's efforts to strengthen radiation worker practices, which were identified as weaknesses during a March 1988 INPO audit and in the licensee's April 1988 corporate QA audit, will also be monitored during future inspections. This latter issue is further discussed in Section 1 These matters were discussed at the exit meetin During plant tours, the inspector observed that two large roll-up doors allowing ingress from outside the plant to the Turbine Building, a part o' the RCA, were maintained open. One door is located at the trackway, the other adjacent to the Maintenance Machine Shop. The inspector alerted the licensee to the potential egress and contamination control problems associated with this practice, particularly the potential for spread of contamination caused by unstable air-patterns during work on contaminated equipment / materials using the machine shop lathe or grinder According to the licensee, this is a normal and acceptable practice and has not created any contamination or egress control problem This matter was discussed at the exit meeting, Hot Particle Events As previously reported (Inspection Report No. 50-155/88004),the licensee identified several hot particles on the refueling deck during surveys performed primarily for that purpose. Since this time (January 1988), about four hot particles have been identified and associated with a cleanup pump removal job performed just prior to the 1988 refueling outage. Cf these four, only one was identified on

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an individual;. skin dose calculations performed by the licensee showed no significant dose was accumulated. The licensee's policy on skin dose determination from hot particles is defined in Section VI of the corporate Radiation Safety Plan. The plan requires a skin dose determination if skin contamination levels greater than 10,000 cpm are observed regardless of the area over which the contamination is spread or the uniformity of contaminatio To calculate skin dose, the licensee uses measured values from Eberline Model R02/R02A dose rate or count rate meters employing Model lip 210/260 probes and recentry revised (Revision 8) the Radiation Safety Plan to require that dose calculations from discrete particles be averaged over 1 cm 2

. This is consistent with NRC IE Information Notices No. 86-23 and No. 87-39 to show compliance with 10 CFR 20.101(a).

Protective clothing is laundered (wet-washed) and surveyed for contamination by a trained janitorial staff membe Conventional hand-held pancake friskers are used for the survey. The licensee's pC release criteria defined in their Corporate Radiation Safety Plan was recently revised to specify a 10,000 cpm release threshold for laundered cloth items surveyed in an unfolded geometry. Although the release criteria was reduced, when geometry considerations and possible clothing attenuation and survey techniques are factored in, this method of monitoring may overlook hot particles of sufficient activity to produce substantial skin dose The licensee has no immediate plars to alter the current methods or equipment employed for PC monitoring; however, the station is considering various monitoring options available and the desirability to segregate clothing used on job: with potential for hot partic1( generatio This matter was discussed at the exit meetin No violations or deviations were identifie . Contamination Event During Non-Destructive Testina (NDT)

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On May 3, 1988, three licensee employees involved in ultrasonic testing of the reactor vessel enclosure studs were unexpectedly contaminated both externally and internally. A C/HP and NDT technician both wearing full-face air purifying respirators worked on the flange level of the i reactor vessel, another C/HP technician without respiratory protection !

monitored the work activity from about 20 feet above tha flange leve l The work reportedly involved only ultrasonic testing and did not entail '

any other activity that could have produced an unanticipated radiological hazard. The ultrasonic tests were reportedly completed in about 30 minutes; no significant radiological problems were identified by the licensee during the jo Just prior to commencing work, the area was wet down to control airborne contaminants. Based on surveys taken during previous refueling outages, the licensee expected relatively high smearable contamination in the work area (about 1 to 5 E5 dpm/100 cm 2

) but no significant airborne concentrations so long as the surfaces remained wet. An air sample taken !

during the job in the immediate vicinity of the testing showed elevated l airborne levels of 2 E-7 uti/ml (nearly 13 MPCs). This was about 100

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times greater than expected. There were no (Job specific) smears or air samples taken prior to the work. The licensee initially attributed the elevated airborne concentrations to greater than anticipated contamination levels and partial drying of the wetted surfaces. According to the licensee, the reactor water cleanup system was not in operation for an extended period since the last entry into the area and additional accumulation and buildup of contaminants may have occurre Low level external contamination was identified on the workers when they ,

attempted to exit the RCA. Whole-body counts performed the following day showed some internal deposition in all three workers; however, no regulatory or licensee administration limits were exceeded. Internal surfaces of the respirators worn by the two workers showed unexpectedly high smearable contamination levels which appear to be inconsistent with the protection factors routinely observed for such respirators during fit testing. The licensee has not fully evaluated the possibility of respirator and filter canister contamination during or prior to the job, or other related avenues to resolve the apparent anomaly. Therefore, this matter is considered to be unresolved pending completion of the licensee's evaluation and subsequent NRC followup (Unresolved Item 155/88014-02). This matter was discussed with the licensee in a telecon on July 7, 198 One unresolved item was identifie . Audits and Appraisals (Ip 83722, 83729)

The inspector reviewed records of audits and appraisals of radiation protection and radwaste program activities conducted from September 1987 to date and discussed the findings and related issues with members of the QA and C/HP Departments. Extent of audits /surveillances and adequacy and timeliness of corrective actions were reviewed. Thus far in 1988, the ,

radiation protection /radwaste programs have been audited by the station's QA/QC group, their corporate office and INP In March 1988, a two-week INP0 audit was conducted at the statio Four findings were identified in the radiation protection area and included the need for increased management attention to resolve l recurrent problems with worker adherence to station radiation protection procedures / practices, contamination control problems, and concerns regarding radiological instrument performance testing and surveys of material released to unrestricted areas. The corrective actions taken or i tentatively planned for those ' findings were discussed with the licensee; no problems were noted with these action In September 1987, a five-day audit of the radiological environmental l monitoring program (REMP) was conducted by the licensee's corporate i office. The audit included a raview of health physics procedures that l implement the REMP to assure they adequately address the technical specifications, maintenance of sample collection equipment, and

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radioactive effluent controls. The audit identified no findings and 1 two observations concerning clarifications and editorial changes to tne l ODC The audit observations were satisfactorily addressed and have since i

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E been closed by the licensee. In April 1988, the corporate office performed a five-day audit of the station's health physics and radwaste packaging .

and shipping programs, focusing on contamination controls and radiation '

worker practices. The audit resulted in no findings and six observations inc % ding previously discussed (Section 8) contamination control problems and a continuing concern regarding radiation worker practices. The audit  !

identified the contamination control program as generally corrective rather than preventative. Improvements were noted in radiation worker practices; however, the audit team identified several isolated occurrences of continued puor worker practices. A similar concern was identified as a finding during the 1988 INPO evaluation. Action items have been established to track corrective actions for all identified observations; corrective actions for some observations are underway. The inspector discussed the desirability for escalating the number and focus of QA/QC '

(unplanned) activity inspections and management observations-(during plant roving) to evaluate ongoing RWP work / radiation worker practice The licensee plans to continue to evaluate radiation worker practices through QA/QC activity inspections and surveillances and has also devised an informal "In-Plant Observation" form to document and trend observations of radiation worker practices and plant housekeeping. This matter was discussed at the exit meeting. The licensee's oversight and program to improve radiation worker practices will be reviewed during a future inspection (0 pen Item 155/88014-03).

No violations or deviations were identifie . Radiological Controls During Spent Fuel Movement The inspector reviewed the radiological controls exercised by the licensee during movement of irradiated fuel. Unlike newer design BWRs, Big Rock Point does not have a drywell or other similar area where workers could be potentially exposed to unshielded irradiated fuel during l defueling. In addition, fuel is housed in a shielded cask during 1 transfer. The insertion and removal of fuel bundles and channels is done through the top of the reactor vessel after removal of the reactor vessel head. Water shielding is provided by flooding the vessel and the refueling extension tank. Fuel bundles and channels are hoisted out of the vessel by an overhead crane and grapple, placed in.the shielded transfer cask and moved over and down into the spent fuel pool. According to the licensee, the transfer cask contains about five to six inches lead l

shielding on all sides which reduces the radiation level from an irradiated ,

bundle to about 10 mrem / hou '

During fuel movement, the refueling platform is placed on the extension tank. The platform has an opening which allows the water filled l lead-shielded transfer cask to pass through into the reactor vesse )

For refueling, the transfer cask is lowered into the extension tank to i a depth sufficient to provide water submergence when irradiated fuel is '

hoisted inside. The cask lower door is opened and the fuel grapple is lowered down through the cask into the reactor. The fuel is then  !

withdrawn vertically from the core up into the cask. The lower door of the cask is closed and sealed and the cask is raised up and out of the vessel area and laterally about 25 feet to the spent fuel storage l I

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pool. A continuous air monitor and criticality and area radiation-monitors (with alarms) monitor the radiological conditions on the refueling deck. A refueling deck drain collects water drippage from the transfer cask and diverts it to the dirty receiver tan Expansion joints on the refueling deck could seep water into the control rod drive (CRO)

rebuild room beneath the refeuling deck; however, according to the licensee, controls are instituted to prevent occupancy of the rebuild room during fuel movement. During fuel movement, the crane operator and control room are in continuous communications. No problems were noted with the radiological controls exercised during fuel movemen No violations or deviations were identifie . Solid Radwaste (IP 84722)

The inspector selectively reviewed the licensee's solid radioactive waste management program, including: general compliance with waste generator requirements in 10 CFR 20.311 and 61.55; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse Solid radwaste handling, compaction, and storage facilities are located in the radwaste building just outside the protected area. The inspector toured the facility, performed independent measurements and discussed radwaste compaction with a licensee representative; no problems were note High activity bead resin and filter media are dewatered by a vendor and shipped in HIC HICs are stored in concrete vaults in the radwaste building pending shipment to a burial site. 10 CFR 61 waste classification is made using the Wastetrak computer software program which uses the scaling factor methodology of AIF/NESP-027, "Methodologies for Classification of Low-Level Radioactive Wastes From Nuclear Power Plants," 1983. The scaling factors are updated by an ongoing actual waste stream analysis program and are used with dose rate measurements of prepared packages to generate manifest The licensee continues its program to segregate clean from potentially >

contaminated DAW using designated waste containers located throughout the RCA. Each bag of clean waste is surveyed with a pancake probe prior to disposal in the clean waste dumpster; the dumpster is maintained locked with keys controlled by the C/HP Department. Dry active wastes are either compacted in 55 gallon drums or placed in large steel bins. The compaction ability of the licensee's compactor has been enhanced with compaction disks that can yield up to about 290 pounds of waste per dru A vendor supplied supercompactor is under consideration, i

The station generated about 1400 cubic feet of solid radwaste in 1986, about 2500 cubic feet in 1987 and nearly 600 cubic feet in 1988 through May. The majority of waste generated in 1986/87 was noncompactible DA In 1988, waste volume was composed primarily of compacted DAW and some filters and resin I I

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1 Liquid Effluents (IP 84723)

The inspector reviewed the licensee's liquid radwaste effluent program, including: determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of-programmatic weaknesse Batch releases from various liquid waste tanks are diluted with the '

service water and the circulating water discharge before release to Lake Michigan. Liquid effluent releases are composed primarily of batch releases from chemical tanks and consist mostly of laundry water and liquid wastes generated from decontamination activities. Chemical tank effluents are normally processed by filtration only. Other liquid batch releases for water quality or inventory control are generally processed by demineralization and filtratio .

The inspector selectively reviewed records of radioactive effluent sampling and analysis for 1988 to date and the semiannual effluent '

eports for 1987. The pathways sampled and analyses performed appear to comply with technical specification requirement Total liquid radioactive effluents released (excluding tritium) during 1987 were about 270 mci compared with 71 mci released in 1986 and about 150 mci each in 1985 and 1984. The major contributor to the activity released in 1987 was from a single dirty waste receiver tank release in July. Total tritium release in liquid effluents in 1987 was about 0.58 curies, somewhat less than the stations average over the previous three years. In 1988 to date, thirty-six liquid batch releases were made totaling about 160 mC1. A large part of these releases are attributable to the nearly completed refueling outag No violations or deviations were identifie . Gaseous Effluents (IP 84724)

The inspector reviewed the licensee's gaseous radwaste effluent program, ;

including: gaseous radioactive waste effluents for compliance with ,

regulatory requirements; adequacy of required records, reports, and ,

notifications; and experience concerning identification and correction of programmatic weaknesse The inspector selectively reviewed records of radioactive effluent ,

sampling and analysis for 1988 to date and the semiannual effluent reports for 1987. The pathways sampled and analyses performed '

appear to comply with technical specification requirement Gases from the air ejector offgas system are monitored by both the air ejector offgas and stack monitors, after a 30-minute holdup, and are released from the stack. Gases from the gland seal condenser pass through a 90-second holdup line before stack monitoring and subsequent release. Gases from the containment (sphere), radwaste area, Turbine Building and Service Building are routed to the stack for monitoring and releas ;

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J The total noble gas released in 1987 was about 8350 curies and is -

significantly less than the previous three year average (nearly 90,000 curies) when continuing fuel cladding problems were experience .0ffgas grab sample results for 1987 showed release rates remaining constant at about 350 uCi/sec (somewhat less than their historical normal rate). In 1988 to date, total noble gas releases have amounted to about 1900 curies; release rates have remained relatively constant at less than 300 uCi/sec. According to the licensee, previous fuel cladding problems have been rectified, problem fuel has gradually been replaced with fuel of a new design and no leaking fuel is currently eviden In 1983, the licensee replaced their existing stack gas monitoring system with an improved Radioactive Gaseous Effluent Monitoring System (RGEM)

to meet NUREG-0578, Section 2.1.8b requirements. The facility change was officially reported in letter dated May 1, 1987. The RGEM system obtains a continuous representative sample of gaseous effluent from the plant stack during normal and emergency conditions. The inspector verified that the RGEM system has the capability to monitor the range of noble gas concentrations advocated in NUREG-0578; no problems were note No violations or deviations were identifie . Effluent Control Instrumentation

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The inspector reviewed channel calibration methodology and records of calibration and functional tests for selected radioactive liquid and gaseous system effluent monitors for 1987 and 1988 to date. This included the air ejector offgas monitors and stack normal range noble gas monitor for the gaseous system and the liquid radwaste effluent monitor for the liquid system. Calibration records of the emergency condenser vent monitors and tests of the high radiation trip closure of the containment ventilation isolation valves was also reviewed. No significant problems were note The licensee continues to calibrate the liquid radwaste monitor using an external solid source at two different distances corresponding to i

, two different radiation fields and compares the monitor response to a previous transfer calibration in which liquid sources were used.

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1982 involved determination of monitor efficiency using three different concentrations of Cs-137 liquid sources and a Co-60 source for dead time determinatio Reportedly in the early 1970's, the licensee initially established monitor energy efficiency using three different liquid sources encompassing a range of gamma energies and based subsequent transfer calibrations using the isotope that produced the more conservative efficiency. This methodology appears adequate and meets technical specification channel calibration requirements. Initial energy efficiency curves generated using three different liquid sources and associated records maintained by the licensee will be reviewed during ,

a future inspection (0 pen Item 155/88014-04).

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Gaseous effluent monitor calibrations continue to be performed as previously reported (Inspection Report No. 155/86006). No problems were note No violations or deviations were identifie :

16. Tours and Observati.ons of Plant Radiologically Controlled Areas The inspector observed housekeeping and radiation protection and contamination conttol practices during plant tours of the Turbine Guilding, Sphere and Radwaste Building. Housekeeping was generally adequate; however, tool controls appeared to be lax throughout the Turbine Building. Contamination and egress control' concerns were previously discussed in Section In addition to there concerns, supplies to control the spread of personnel contamination (shoe covers, gloves etc.) detected at the sphere and personnel hatch frisking stations were not available. Also, plastic bags used for collection of used PCs were taped to walls and piping in the turbine building basement and not rigidly supported; this latter concern was previously identified (Inspection Report 155/88004). These matters were discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item 155/88014-05).

The inspector performed direct radiation and smear surveys of equipment, i tools, and in selected areas of the Turbine and Radwaste Buildings and Sphere. Survey results were consistent with licensee posting ,

No violations or deviations were identified.

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17. Exit Meeting (IP 30703)

The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on June 24, 1988, and further discussed issues related to the contamination event dircussed in Section 9 in a  !

telecon on July 7,1988. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar The inspector specifically discussed the following matters, The desirability to identify the root cause(s) of the numerous low-level personnel contamination events and continue efforts to strengthen contamination controls. (Section 8(a)) Potential Turbine Building contamination / egress control problems associated with open roll-up doors in the area. (Section 8(a))

! Monitoring of laundered clothing (Section 8(b)).  ; Oversight of radiation worker practice (Section 10) l

! General plant housekeeping and related contamination control issue (Section 16) I

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