IR 05000255/1978021
| ML18043A335 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/14/1978 |
| From: | Fisher W, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18043A333 | List: |
| References | |
| 50-255-78-21, NUDOCS 7812200302 | |
| Download: ML18043A335 (11) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/78-21 Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, MI Inspection Conducted:
September 21-22 and 26-29, 1978
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UUC::L...C:.. Approved :By:
W. L. Fisher (September 21-22, 1978)
'JI ~r::l~ef Fuel Facility Projects and Radiation Support Section Inspection Summary 11 /1v/2~
Inspection on September 21-22 and 26-29, 1978 (Report No. 50-255/78-21)
Areas Inspected:
Routine, unannounced inspection of radioactive waste systems, including:
effluent releases; records and reports of effluents; effluent control instrumentation; procedures for controlling releases; containment air-cleaning systems; reactor coolant water quality; solid radioactive waste; review of noncompliance corrective actions and a licensee event report; review of a licensee reported overexposure; and review of two IE Circulars and two IE Bulletin The inspection involved 65 inspector-hours onsite by two NRC inspector Results:
Of the ten areas inspected no items of noncompliance or deviations were identified in eight area One apparent infraction was found in the area of effluent control instrumentation (Paragraph 7)
and two apparent infractions were found associated with the reported overexposure of an employee (Paragraph 14).
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- DETAILS Persons Contacted
- J. Lewis, Plant Superintendent
- V. Shockley, Health Physicist
- T. Neal, Radiological Materials Control Supervisor T. Meek, Associate Health Physicist D. Kozin, Plant Laboratory Supervisor S. Pierce, Senior Chemistry Technician C. Smith, SRO Plant Shift Supervisor II-Nuclear The inspectors also contacted several other licensee employees, including auxiliary operators and mechanical maintenance me *Denotes those present at the exit intervie.
General This unannounced inspection began about 10:00 a.m. on September 21, 197 Several tours were made of the plant during the inspection with emphasis on the areas involving the radwaste systems and handling area Housekeeping appeared cluttered in the decontamination room, where work on Control Rod Drives was in progres Aside from this area, housekeeping appeared to be satisfactory in the areas toure The licensee continues to solidify evaporator bottoms, using the PPI syste This system uses urea formaldehyde and a catalys The containers are still drained following solidificatio Drainage varies from about 15 to 40 gallons per 50 cubic foot waste line Licensee Action ort'Previous Inspection Findings (Closed) Infraction (50-255/77-13):
Type B quantities of byproduct material were delivered to a carrier for transport without authori-zation by the Commissio Review of radioactive material shipments from the time of the referenced inspection through June 30, 1978 showed that all shipments were made with proper authorizatio Licensee actions regarding items identified in Investigation Report 50-255/78-16 in general were not reviewed during this inspectio However, the inspector was advised that completion of installation of the fence restricting access to the new solid radioactive waste storage building and truck trailer loading area was accomplished on September 27, 197 These items will be reviewed during a future inspection.
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4. Gaseous Effluents A review of gaseous effluent records for the period July 1977 through June 1978 revealed no instances of exceeding technical specification limits for gas or particulate effluent Although laboratory procedures for specific radionuclide analyses were not reviewed, the results of waste gas batch analyses and stack sampler analyses were reviewe The only potential problem observed was the lack of Kr-85 data for many gas sample The licensee attributes this to Kr-85 concentrations being less than the minimum concentration detectable by current methods and equipment. lfhe question of Kr-85 sensitivity has been raised previously.-
The licensee has installed a more sensitive GeLi system and is considering additional steps to improve. sensitivity._~/
No items of noncompliance or deviations were identifie Liquid Radioactive Effluents Licensee records of liquid releases were reviewed in detail for the first calendar quarter of 1978 and cursorily for the third and fourth quarters of 1977 and the second quarter of 197 All releases appear to have been made in accordance with regulatory requirement The Turbine Room Sump continues to be the major contributor to liquid radwaste volum Trace levels of tritium and occasionally trace levels of other nuclides are identified in this liqui Laundry continues to account for the major portion of nuclides released with the exception of tritiu No items of noncompliance or deviations were identifie.
Effluent Reports A comparison of selected gaseous effluent records and the licensee's semiannual effluent reports for the periods July through December 1977 and January through June 1978 revealed no reporting problems, except possibly for Kr-85 as discussed in item As stated in these semiannual reports, gaseous effluents were released at a very small fraction of the rate allowed by the technical specification A comparison of selected liquid effluent records and the licensee's semiannual effluent reports for the same period listed above showed no reporting problems, except in reporting the percent of Technical Specification limit for: Fission and Activation Products (both first and second quarter of 1978) Tritium (second quarter of 1978)
1/ IE Inspection Report 050-255/77-13 2/ IE Inspection Report 050-255/78-20
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- Dissolved and Entrained Gases (first quarter of 1978)
However, the total percent of limit was listed correctly for each quarte The report preparer apparently neglected to mul-tiply the numerator by 100 in determination of a percentage in the cases cited abov As indicated in these semiannual reports, liquid effluent releases were a small fraction of that allowed by the technical specification No items of noncompliance or deviations were identifie.
Effluent Control Instrumentation The licensee has no iodine monitors which could be affected by noble gase However, an iodine monitor is being purchase The effect of noble gases on this monitor will be considered during a future inspectio Gaseous process monitors have been calibrated at the frequencies specified in Technical Specification 4.1, except for the West Engineering Safeguards Gas Monitor, RE-181 Although Technical Specification 4.1 (Table 4.1.3) requires calibration of process monitors at least once per 18 months, the licensee's records showed no calibration of RE-1811 between April 16, 1976 and June 21, 1978, a period of 26 month The licensee's Event Report, PAL-78-029, identifying the problem by internal audit was not issued until April 24, 1978, (over 24 months from the previous calibration) and calibration was not accomplished until about two months later (June 21, 1978).
Calibration records showed that RE-1113, the Waste Gas Monitor, was last calibrated on December 16, 197 However, the instrument was not calibrated above about 21,000 counts per minute, even though it sometimes operates at much higher count rates during gaseous release For example, during the release of Waste Gas Decay Tank T-68B on December 15, 1977, the high count rate required an RE-1113 alarm setpoint of 570,000 counts per minut Technical Specification 1.3 defines channel calibration as "Adjustment of channel output such that it responds, with acceptable range and accuracy, to known values of the parameter which the channel measures."
Since the calibration did not cover the required range, the calibration did not satisfy the requirement of Tech-nical Specification 4.1 (Table 4.1.3).
The inspector discussed with the licensee the effect of a highly variable background (approximately 3,000 to 75,000 counts per minute in 1977) upon the sensitivity and alarm setpoint accuracy of RE-1113, the Waste Gas Monito The effect on sensitivity appears to be small, because the waste gas is undiluted at the monitoring poin The effect on alarm setpoint accuracy is small at high alarm setpoints, but could be large at low alarm setpoint The latter condition does not appear to be a problem,
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- however, because release rates permitting low alarm setpoints are considerably below the technical specification release rate limi Licensee personnel attributed the high bac_kground of the gas monitor to moisture problems in the waste gas monitor line which occurred for about a six-week period in late 197 After cor-rection of the problem the *background count rate of the 'monitor has not exceeded about 6,000 cp Liquid process monitors appear to have been calibrated over the usable range of the instruments and at the frequencies specified in Technical Specification 4.1, as determined from review of licensee calibration records, with one exceptio Volume Control Tank Monitor RIA-202 was last calibrated April 17, 197 Licensee personnel stated that when attempts were made to perform the calibration at the last refueling it was learned that valves would have to be welded into the Seismic Class 2 system before the calibration could be accomplishe It was further stated that a Quality Control material search was needed prior to the valve installatio An Event Report, PAL-78-029, dated April 24, 1978, was issued by the licensee regarding the matter; however, calibration had not been accomplished as of completion of this inspection on September 29, 1978. The long overdue calibration does not satisfy the requirement of Technical Specification (Table 4.1.3).
The inspector noted that there is no automatic termination of liquid radwaste releases in the event of loss of dilution flo Further, liquid radwaste release procedures and forms do not appear to instruct or caution workers involved with the release to terminate the release under such circumstance Licensee personnel agreed to review this matte One item of noncompliance (with three examples) and no deviations were identifie Solid Radioactive Waste Solid radioactive waste shipment records were reviewed for the period September 1977 through June 1978, and the data compared with corresponding semiannual effluent report No problems were note Evaporator concentrates solidified with urea formaldehyde in 50 cubic foot Type A containers are shipped in "sole use" trucks to licensed burial site Dewatered resins are shipped in essentially identical container Of the shipment records reviewed, only two were observed to have packages containing greater than Type A quantities of radioactive materia These two shipments, occurring in February 1978, con-tained reactor incores having large quantities of cobalt 6 The package containment and radiation levels associated with the packages appeared in both cases to meet regulatory requirement _,
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No items of noncompliance or deviations were identified *
Radwaste Solidification System History The licensee uses a urea formaldehyde-catalyst system for solidi-fication of evaporator concentrates onl The evaporator is used on essentially all liquid radwastes having significant radio-activity, except laundry water due to the problems caused in evaporators by the cleansing agents in laundry wate The solidification system was a part of the radwaste addition, which was retrofitted to the plant in April 197 No waste solidification took place before that tim The solidification system was designed to be fully automati The licensee, unable to control the product using the automatic mode, has continued to operate the system in a semiautomatic mod E.ach step is initiated remotely from the control pane The level indicator and the automatic shut-off are not use The necessity to control pH of liquids containing boric acid before eyaporation results in liquids for solidification having a pH over a limited rang The amount of catalyst needed to solidify over this range has been determined and the amount of urea for-maldehyde and catalyst needed are pumped (based on feed flow rate charts) for the mixtur A probe is manually used shortly after filling the container to ensure that "set-up" is progressin According to licensee personnel, problems with 11set-up 11 are usually attributed to pump component failures, which are then corrected by maintenanc The filled 50 cubic foot liner is allowed to physically cool and "set-up" for about two day Since the licensee learned about two years ago of drainable liquid in the liner, the liners are tilted on a stand for two or three days following the "set-up" period and free liquid is allowed to drain from the liner through a half inch drain plug near the bottom of the line Drainage volume typically ranges from 15 to 40 gallon A new fiberglass tank for the catalyst was installed about one and one-half years.ago, as the original tank had corroded and leake The licensee is evaluating two other solidification systems for possible replacement of the current syste The two systems are the DOW system and an asphalt syste Exposure of personnel operating the system in 1977 is estimated to total about 1 to 1.5 rem As all of the evaporated waste is first filtered and some is cleaned with resin, the activity of the evaporator concentrates is relatively lo Radiation levels near the surface of the solidified containers typically is about 20 mR/h *6 -
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About a year ago the licensee had Delaware Custom Material Company come on site to demonstrate-solidification.of oily liquids (not compatible with the urea formaldehyde system)*and other materials in 55-gallon drums, using a modified cement system. This system was also evaluated as a back-up to the current system should the need arise.* This system appeared -to work but involves more manual operation than the current syste No items of noncompliance or deviations were identifie. * Radwaste Control Pro*cedures The inspector reviewed the following selected radwaste control procedures:
H.P. 6.3 Revision 4, 9/19/77
"Laundry Radwaste Batch Calculation and Release Authorization" H.P. 6.4 Revision 5, 10/13/77 "Modified Radwaste Calculation and Release Authorization" H.~~ 6.7 Revision 4; 4/17/78
"Calculation of Waste Gas Decay Tank" No problems were noted in the revie.
Containment Air Cleaning*systems Licensee records of in-place penetration tests for HEPA and charcoal filters were reviewed for the period September 1977 through August 1978 ;for the Fuel Pool Filter System, the Control Room Isolation Filter System, and the Containment Post Accident Filter Syste Technical Specification*4.2 (Table 4.2.2) requirements appear to have been me No items of noncompliance or deviations were note.
Reactor Coolant Radiochemistry The licensee's primary coolant radiochemistry records for the
- first nine months of 1978 were selectively reviewe Dose equiva-lent I-131 averaged about 3.SE-2 )JCi/g and gross activity averaged about 6E.-l J.ICi/ The latest E, run on June 23, 1978, yielded a value of. 0.78 Me The licensee's E calculation includes all nuclides (except for iodines which are excluded by technical specification} identified at concentrations of greater than lE-5 pCi/ No items of noncompliance or deviations were identifie "*'.
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1 Secondary Coolant Radiochemistry 1 The licensee's secondary coolant radiochemistry records for the five-month period April through August 1978 were reviewe Dose equivalent I-131 did not exceed 2E-6pCi/g and gross activity did not exceed 2.4E-6 pCi/g during the perio No items of noncompliance or deviations were identifie Reported Overexposure of Employee By letter dated April 21, 1978, the licensee reported an exposure of 3.26 rems whole body dose, as determined from film badge readings to a repairman at Palisades during the:first quarter of 197 In substance, the report noted that an investigation con-ducted by the licensee indicated the whole body dose received was not as high as indicated by the film badg However, based on the licensee's policy to accept the film badge as legal record of dose if worn continuously in the radiation area, the 3.26 rem dose was being considered official by the license Most of the individual's exposure, and that which resulted in exceeding 3 rems for the quarter, occurred while performing maintenance in a pipe-way located at elevation 602' in the Auxiliary Buildin Appropriate occupational dose history information had been obtained for the worker authorizing a whole body dose up to 3 rems for the calendar quarte Receipt of a whole body dose exceeding 3 rems (3.26 rems) by the maintenance worker during the first calendar quarter of 1978 constitutes apparent noncompliance with 10 CFR 20.lOl(b).
During this inspection the individual who received the over-exposure, a co-worker, and the individual responsible for supervising the work activity when the overexposure occurred were interviewed. It was learned that the individual responsible for supervising the activity on valves, a Senior Laboratory Technician, had to do initial work on each valve, final work on each valve and sometimes interim work to coincide with that performed by the maintenance men working for hi The Senior Laboratory Technician received training in monitoring for radi-ation and other specified training and was considered exempt from the requirements for a Radiation Work Permit (RWP) for control of work within a restricted are The maintenance men were not trained or designated as RWP exempt and were not working under an RWP nor under the direct supervision of a member of the Radi-ation Protection Group nor, at the time of the occurrence, under the direct supervision of the individual responsible for super-vising the work activit Health Physics Procedure 1.1.2.21
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- specifies that all personnel not specifically authorized for RWP exemption must have radiation work permits for all work within a restricted area. It further states that direct supervision by the Radiation Protection Group can replace the RW Therefore, the licensee is in apparent noncompliance with Technical Specification 6.11.1, which requires adherence to radiation pro-tection procedures, in that procedure H.P. 1.1.2.21 was not fol-lowed on February 23, 1978, when three maintenance men, who were not specifically authorized for RWP exemption, worked within a restricted area without a radiation work permit or direct super-vision by a member of the Radiation Protection Grou Two items of noncompliance and no deviations were identifie.
LER 77-56 The inspector reviewed the gaseous effluent release aspects of the main exhaust fan trip which occurred during a waste gas release on November 29, 197 No release rate limits were exceede No items of noncompliance or deviations were identifie.
IE Circular 77-14 In response to IE Circular No. 77-14 issued November 28, 1977, the licensee conducted the requested review to identify inter-connections between contaminated and noncontaminated water systems to ensure that proper separations have been provide The heating steam system is considered the most likely source of contamination of the hot domestic wate Three separation barriers would have to be breeched simultaneously for this to occu As an additional precaution, a liquid sample from the heating steam system is collected and analyzed weekly for tritium and gamma emitter The inspector has no further questions on this matte No items of noncompliance or deviations were identifie.
IE Circular 78-03 IE Circular 78-03 dated May 12, 1978, cautioned licensees of the differences between 10 CFR Part 71 and 49 CFR 170~189 regarding requirements for the type of container when LSA material in excess of a Type A quantity is involve No written response was require The licensee had been aware of the differences for over a yea As noted in Paragraph 8, shipment records were reviewed from September 1977 through June 1978 with no problems being identified.
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1 IE Bulletin 78-07 By letter dated August 3, 1978, the licensee responded to IE Bulletin No. 78-07 issued June 12, 1978 regarding protection afforded by air-line respirators and supplied-air hoods, As stated in the response, the licensee does not use demand mode operated air-line supplied-air respirator The licensee does have supplied-air hoods, which have not been used since issuance of the bulleti Further, the licensee stated that these hoods will not be used until verification that the flow rates provided meet those recom-mended in the bulleti No problems were identified with the licensee's actio.
IE Bulletin 78-08 By letter dated August 11, 1978, the licensee responded to IE Bulletin 78-08 dated June 12, 1978, regarding radiation levels from fuel element transfer tube The licensee completed a review of shielding design and concluded that no unshielded areas exist anywhere along the length of the fuel transfer tub The licensee identified three areas where measurable radiation levels might occur from multiple scatter radiations during fuel transfe The licensee stated that radiation levels at these locations will be measured by appropriate means during the next refueling outag The results of these measurements will be reviewed during a subsequent inspectio No items of noncompliance or deviations were identifie.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on September 29, 1978, and subse-quently contacted Mr. Lewis, Plant Superintendent, by telephone on October 27, 197 The inspector discussed the scope and findings of the inspectio The following matters were specifically discussed: The apparent item of noncompliance regarding the calibrations of the Waste Gas Monitor, the Volume Control Tank Monitor, and the West Engineering Safequards Monitor failing to satisfy the requirements of Technical Specification 4.1 were discusse Regarding the limited range over which the Waste Gas Monitor was calibrated, licensee personnel stated that they had no higher concentrations of waste gas at that tim The licensee further stated that a new calibration would be performe Regarding the West Engineering Safeguards Monitor, licensee personnel stated that the delay in calibration was due to the monitor being out of service for maintenanc Licensee personnel also noted that this air stream feeds into
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- another alarm monitored system (Radwaste Building Exhaust Plenum).
Regarding the long overdue calibration of the Volume Control Tank Monitor, licensee personnel stated that a Quality Control material search was needed before valve installation which in turn was needed before performance of the calibratio It was stated that valve installation and calibration should be accomplished soo (Paragraph 7)
The inspector noted that the licensee's system does not pro-vide for automatic termination of liquid radwaste release in the event of loss of dilution flo Further, the release procedures and forms do not appear to instruct or caution workers involved to terminate the release should loss of dilution flow occu Licensee personnel agreed to review
.this matte (Paragraph 7)
The apparent item of noncompliance regarding the overexposure of a worker during the first calendar quarter of 1978 was discusse The licensee stated that their investigation indicated that the dose received by the whole body was not as high as that indicated by the film badge which is considered as legal record for dos (Paragraph 14)
Related to the above item of noncompliance, an apparent item of noncompliance involving failure to follow procedures for use of the radiation work permit for control of work within a restricted area was discusse (Paragraph 14)
The inspector noted the continuing licensee problem of detecting Kr-85 in gaseous radwaste even w1th the recent installation of a more sensitive GeLi syste The licensee confirmed that other measures will be taken to increase sensi-tivity for Kr-85 in gas sample (Paragraph 4)
As a result of interviews with licensee personnel the inspector discussed with licensee management the necessity for good communications in the area of radiation safet This matter will be pursued further during a subsequent inspectio The licensee agreed to submit corrected data with the next semiannual report regarding some errors identified for the liquid effluent data reported for the first and second quarters of 197 (Paragraph 6)
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