IR 05000255/1981027
| ML18046B246 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/22/1982 |
| From: | Greger L, Hueter L, Lovendale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18046B245 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-255-81-27, IEIN-79-08, IEIN-79-8, NUDOCS 8202050240 | |
| Download: ML18046B246 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/81-27 Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 License No. DPR-20 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, MI Inspection Conducted:
December 7-11, and 16, 1981 Inspectors: ~
P. C. Lovendale (~/H
'/1J&uq*v'-
Approved By:
L. R. Greger, Chief Facilities Radiation Protection Section Inspection Summary Inspection on December 7-11 and 16, 1981 (Report No. 50-255/81-27)
Areas Inspected:
Routine, unannounced inspection of licensee actions taken in response to Health Physics Appraisal finding It also included a review of transportation activities, certain TMI Action Plan items, out-standing inspection items, allegations concerning radiation work permits, and licensee responses to a cooling tower overflow event and a primary system lea The inspection involved 98 inspector-hours onsite by two NRC inspector Results:
No items of noncompliance or deviations were identifie PDR ADOCK 05000255 G
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- DETAILS Persons Contacted R. Montross, Plant General Manager
- A. Kowalczuk, Chemistry and Health Physics Superintendent
- G. Petitjean, Technical Engineer
- W. Mullins, Plant Health Physicist L. Kenaga, Radiation Protection Supervisor N. Campbell, Radiation Protection Supervisor W. Wattson, Health Physicist - ALARA R. Clendenning, Radiation Protection Supervisor P. Stoner, Health Physicist C. Kahn, Senior Chemist S. Pierce, RMC Supervisor
- J. Rang, Plant Operations/Maintenance Superintendent N. Hough, Training Superintendent Bo Jorgensen, NRC Senior Resident Inspector
- J. Heller, NRC Resident Inspector The inspectors also contacted other licensee employees and contractors including radiation protection technician *Denotes those present during the exit meetin.
General This inspection, which began with participation in orientation train-ing for unescorted access at 8:00 a.m. on December 7, 1981, was conducted to examine licensee actions taken in response to the Health Physics Appraisal, transportation activities, outstanding inspection items, allegations concerning radiation work permits, and licensee progress on certain TMI Action Plan item Also, the inspectors monitored licensee actions taken in response to a cooling tower over-flow event and primary system lea.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance Item (50-255/79-16-01):
Transfer of a drum containing about 35 gallons of free liquid radioactive material to a waste burial facility which was not authorized to receive free liqui Chemical analysis of the water indicated that the liquid was rain water containing low level radioactive contaminatio The licensee's correc-tive actions included procedural changes providing detailed guidance in proper methods of radwaste handling, packaging, and preparation for shipment, and in regulatory requiremets and burial site disposal criteri The prohibition of liquids in radwaste containers was further addressed in quality assurance procedures and required checks for presence of liquid before closing radwaste container As a further precaution, liberal amounts of absorbent materials are now placed in radwaste container The licensee's actions appear appropriat. ~'
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(Closed) Noncompliance Item (50-255/79-16-02):
Failure to log data from the free liquid leakage check of containers of UF solidified evaporator bottoms as required by procedur The licensee's corrective actions included terminating the use of the UF process for solidifi-cation of radwaste and replacing it with the Delaware Custom Material Silicate Solidification Syste The licensee has had fewer problems with free liquid using the new proces In addition, documented checks for evidence of free liquid are made and liberal amounts of absorbent material are added to the package as a final precautio The licensee's actions appear appropriat (Closed) Noncompliance Item (50-255/79-19-02):
Failure to conduct a procedurally required whole body count of an individual upon termina-tion of employmen The former employee was returned to the plant for a whole body count in December 197 The analysis showed no indication of approaching the 40 MPC-hour control measure specified in 10 CFR 20.103(b) (2).
(Closed) Noncompliance Item (50-255/79-19-04):
Failure to make a proper evaluation for presence of radioactive material in plant refuse (powdered resin wastes) being released to a landfill for buria The licensee's corrective action included:
Sending all powdered resin wastes to a licensed radwaste burial facility; conducting daily surveys of dumpsters to confirm the absence of contaminated plant refuse; and conducting surveys of all vehicles leaving the site and logging the survey result The corrective actions appear* appropriate.
(Closed) Noncompliance Item (50-255/81-06-01):
Some 55 gallon drums containing contaminated material were found stored in the onsite over-flow parking lot, an unrestricted are Although we do not agree with the licensee's statement in their response dated June 15, 1981, contend-ing that certain "controls" observed by the licensee serve to qualify the overflow parking lot as a restricted area, corrective actions taken by the licensee appear appropriat These corrective actions included:
conducting a detailed survey of the area and materials and promptly returning all contaminated items to the protected area; instructing technicians of the necessity for thorough surveys of all materials upon removal from the protected area, and initiating a semi-annual survey of this and other areas outside the protected are No further problems were identifie (Closed) Noncompliance Item (50-255/80-14-09):
Failure to follow radi-ation protection procedure The inspector reviewed the licensee's response and actions taken to improve procedure adherenc No problems were note (Closed) Open Item (50-255/79-19-01):
Further evaluation was needed to determine if one individual may have exceeded the 40 MPC-hour control measure specified in 10 CFR 20.103(b)(2).
Several whole body counts had been conducted on October 10 and 11, 1979, of the contractor-3-
- employee involved in inspection work in containmen Evaluation of the additional data obtained demonstrated that the worker did not exceed the 40 MPC-hour control measur.
Transportation Activities The licensee's program for receipt, packaging, and transport of radio-active materials was reviewed by the inspecto Procedure HP. 6.18, Revision 7, "Radwaste Procedure - Low Level" and Procedure HP 6.20, Revision 2, "Radioactive Material Shipment" were reviewed and compared with the requirements of 49 CFR 170-189 and 10 CFR 7 No problems were note Randomly selected recent radwaste shipment records were reviewe No significant problems were identifie Minor concerns identified were discussed with licensee personne The licensee is progressing on installation of a Werner Pfleiderer waste solidification system which uses asphalt as the solidification mediu The system will utilize the old UF facility plus an expansion are Major components are in place and a concrete shield wall has been poure The electrical work remains to be don Licensee personnel expressed hope of beginning test operation of the system in June 198 No items of noncompliance were identifie.
Licensee Event Followup The following Licensee Event Reports (LER's) associated with gaseous releases were reviewed including verification of the quantification of activity released and determination of the release rate as a percent of applicable release rate limits (annual average and fifteen minute)
specified in the technical specifications:
LER's 255/79-31-03; 255/79-35-03; 255/80-25-01; 255/80-27-01; 255/80-36-01; 255/80-40-01; and 255/81-32-0 No discrepancies were identifie IE Information Notice No. 79-08 During a previous inspection 1 it was noted that the licensee had not completed a review of interconnections between contaminated systems and the Service Air System which is used as a source of breathing ai The licensee's review was completed in mid-198 Six interconnections were identified with each having a check valve and either one or two closed globe valve Interconnecting systems were opened and2smear surveys conducted; all smears showed less than 120 dpm/100 cm.
The review concluded that no modifications were needed based on the separa-tion provided and evidence of no significant contamination past the interconnecting bourdaries after years of service. It was noted, how-ever, that in response to IE Bulletin 80-10.the licensee initiated a-4-
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routine sampling of the service air system at a location likely to detect contamination if the source of intake air for the compressor was contaminate Following discussion of the matter, licensee personnel stated that locations downstream of the six interconnections will be selected for periodic contamination surveillance that should detect contamination originating from the identified interconnection (50-255/
79-19-03).
IE Circular No. 79-09 This circular described action that should be taken due to problems with regulator diaphram failures in Scott Air Pak II/IIA and Presur Pak II/IIA self-contained breathing equipmen No action was required since the licensee does not possess this specific equipmen IE Circular No. 79-15 This circular described actions thit should be taken due to problems with bursting of high pressure hose and malfunction of relief valve "O" ring in Surviv Air Mark I self-contained breathing equipmen No action was required since the licensee does not possess this specific equipmen IE Circular No. 81-09 The inspector reviewed the licensee's actions in response to IE Circular No. 81-09, "Containment Effluent Water that Bypasses Radio-activity Monitor".
The licensee conducted an evaluation of all con-tainment penetrations and concluded that no significant potential existed for unmonitored and/or nonisolable release to the environment during a design basis acciden The inspector reviewed the evaluatio No problems were note Overflow of Cooling Tower Basin While filling the cooling tower basin on December 6, 1981, a valve position indication malfunction resulted in overflow of the basi The licensee estimated that 250,000 gallons of water overflowed the basin and flowed across the south side of the site and then into the lake via the yard drain system and turbine building sum A radwaste packaging and storage building, in the path of the overflowing water, was partially floode The licensee sampled the water remaining in the radwaste building and determined the gross concentration of radioactivity to be about.* lE-5 microcuries per millilite Additional samples were taken south (upstream) of the radwaste building and about 200 feet north (downstream)
of the radwaste buildin No radioactivity was detected in the sample lf IE Inspection Report No. 50-255/79-19.
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No samples were taken downstream in close proximity to the radwaste building, or from the yard drain catch basins close to the radwaste building, until prompted to do so by the inspectors on December 8, 198 These samples were necessary to determine if radioactivity from the radwaste building had washed from the building to the surrounding area and storm drain system which drain to the lak Sand samples, collected on December 8, 1981, close to the radwaste building showed a maximum gross radioactivity concentration of about lE-4 microcuries per gra Also, sand samples taken on December 8 and 9, 1981, from below the lake discharge of the storm drain system and a ditch which drains to the lake, showed a maximum gross radioactivity concentration of about lE-6 microcuries per gra A portion of the ditch sample was analyzed on December 14, 1981, using NRC counting equipmen This analysis confirmed the results obtained by the license Based on the sample results, it appears that a release to the unre-stricted area (lake) did occur, but it is unlikely that the radwaste building was the source of the radioactivit The licensee is collecting samples from the entire area in an attempt to identify the source of the radioactivit This matter was discussed during the exit meeting and will be reviewed duri~g a future inspectio (255/81-27-01) Initial Indoctrination Training On December 7, 1981, the inspectors participated in the licensee's initial indoctrination training which is presented to all persons requiring unescorted acces This training is conducted by the training department which apparently reports directly to the corporate offic The radiation protection portion of the training utilizes a videotaped presentation supplmented by handouts and instructor revie This training appears to meet the requirements of 10 CFR 19.12 "Instructions to Workers".
Although the method of presentation was generally good, the videotape needs significant updating as evidenced by the instructor's need to verbally correct its content concerning present plant practices and other editorial error The instructor for the radiation protection section of the training was recently hire He has no formal health physics training, and no nuclear plant experience except for a two week assignment to the plant health physics grou The instructor's lack of training and experience was evidenced by several misstatements made during the training. It was also noted that the instructor was not totally familiar with current plant procedures and equipmen He was unsure of plant personnel contamination monitoring and radiation work permit initialling requirement Also, he apparently was not cog-nizant of the new walk-thru portal monitors installed in the gatehous Matters which need correction include:
the need for upgraded videotapes; the need for interface with the plant health physics group to ensure that-6-
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instructors are cognizant of current plant practices and equipment; the need for qualified instructors who have both formal and on-the-job health physics training; and the need to assign audit and oversight functions to the plant health physics group to ensure workers are receiving current and accurate informatio There matters were dis-cussed with the Site Training Manager on December 11, 1981, and during the exit meetin These matters will be reviewed further during a*
future inspectio (255/81-27-02)
1 Primary System Leak On December 11, 1981, a primary system leak was discovered near the top of the reactor pressure vesse The plant was heating up following an extended shutdow The leak rate was estimated at 30 gallons per minut The inspector monitored actions taken by licensee health physics personnel and provided information to the Region III Incident Response Center using the Health Physics Networ Plant health physics response to this event was goo Appropriate air samples were taken inside containment and workers entering containment were provided with appropriate protective clothing and breathing apparatu Airborne activity levels remained below maximum permissable concen-trations and there were no significant radioactive releases as a result of this even No problems were note.
Health Physics Appraisal Followup The inspector reviewed licensee actions taken in response to the Health Physics Appraisal (IE Inspection Report No. 50-255/80-14).
The licensee's response to the appraisal is contained in letters dated January 30, April 7, May 27, and July 2, 198 Included was a review of the Corporate Radiation Protection Standards which were completed in June 198 Licensee corrective actions for Significant Appraisal Findings Nos. 1, 3, 4, 5, and 6 included development of a plant radi-ation protection plan to supplement the corporate standards and develop-ment of plant radiation protection plan implementing procedure The licensee has committed to completion of these actions by the end of 198 However, it appears that this commitment will not be me The licensee stated that a revised schedule will be submitted to the NRC in the near futur These items will be reviewed during future inspection (255/80-14-01; 255/80-14-03; 255/80-14-04; 255/80-14-05; 255/80-14-06) Corporate Radiation Protection Standards A cursory review of the licensee's Corporate Radiation Protection Standards was conducted to determine if they are consistent with the requirements of 10 CFR 20, good health physics practices, and previous licensee commitment The inspector noted the following problems:
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Section IV.2.6 "Training Programs" lists the minimum training requirements for visitors and radiation workers.
The program description for escorted visitors and persons requiring unescorted access to the protected (restricted)
area does not reference the requirements of 10 CFR 19.12
"Instructions to Workers".
The program description for basic radiation worker training references 10 CFR 19.12 requirements for persons requiring routine or frequent access to controlled area This appears to be inconsistent with 10 CFR 19.12 which applies to all individuals working in or frequenting any portion of a restricted are (2)
The definition of an unrestricted area in Section V, Part 1, Paragraph 2.1.2, should include some discussion of unre-stricted area allowable radiation levels listed in 10 CFR 20.10 (3)
Section VI, Part 2, Paragraph 2.3.1 and 2, states that per-sonnel exiting a radiation controlled area shall be subject to contamination monitorin Also, it states that a portal monitor shall be used, where installed, for the purposes of contamination monitorin Portal monitors should not be used for primary personnel contamination monitorin If personnel contamination monitoring is necessary, it should be accomplished by the use of "friskers" capa~le of detecting low level*
contamination (3000 dpm/lOOcm * is used in current guidance).
The licensee's portal monitors are not capable of detecting these level Also, Paragraph 2.3.2, 4 and 5 states that persons "should" be monitored, and that material "shall" be monitore This wording implies that it is more important to monitor material than it is to monitor worker (4)
Section IV, Part 3, "Airborne Radioactivity" does not address sampling for airborne tritiu (5)
Section VI, Part 5, "Bioassay Requirement" is very restric-tiv The plant health physics group may want the flexibility of waving entry and termination whole body counts based on an individual's work location, etc., if other requirements of 10 CFR 20.103 are me (6)
Section VII, "Radioactive Materials Control," uses 10 CFR 20 Appendix B Table II and Appendix C for unrestricted release concentration and quantity limit This is an inappropriate use of these appendice Until further guidance is available, material containing detectable radioactive material that originates from the licensee's facility cannot be released for unrestricted us Further reviews of these standards will be conducted during future inspection (255/81-27-03)
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- Radiation Protection Technician Training The Health Physics Appraisal noted that significant improvements were needed in radiation protection technician trainin As of the end of August 1981, seven technicians had attended a 12-week basic chemistry and health physics course that was presented at the Midland Plan Other technicians have been unable to attend due to the extended outag A few technicians will attend the basic course in March 198 Also, a few technicians will attend a 12-week advanced chemistry and health physics course which is also being conducted at the Midland Plant starting in March 198 Although the licensee's goals for completing this training have not been met, it appears that significant improvements have been made since the Health Physics Appraisa Progress in this area will be reviewed during a future inspectio (255/80-14-02) Airborne Effluent Quantifications The Health Physics Appraisal noted needed improvements in the licensee's airborne effluent quantification progra The inspector reviewed the licensee's response and actions taken to improve the progra Procedures were developed and training conducted so that releases can be quickly and correctly quantifie No problems were note (255/80-14-07)
1 TMI Action Plan Items Licensee actions in response to NUREG-0737, Items II.B.2, II.B.3, II.F.1, and III.D.3.3, were reviewe The licensee's written response to NUREG-0737 is contained in letters dated December 19, 1980, and February 25, September 28, and July 7, 198 Design Review of Plant Shielding (II.B.2.1)
The plant shielding design review has been complete Several areas of concern were identified, including:
(1). Radiation streaming into the control room and technical support center (TSC) from both 48 inch containment purge duct (2). Direct radiation from containment penetrations in the engineered safeguards room where manual operation of the safety injection system valves is require (3). Access to lab area hindered by direct radiation from containment through the personnel air loc (4). Direct radiation from containment penetrations in the area of the manual operator for safeguards valve CV-3006.
-9-Design Review of Plant Shielding (II.B.2.2.B-Plant Modifications)
All required modifications needed to correct identified shielding deficiencies are close to completio At the time of this in-spection the licensee expected to have all modifications complete by January 1, 198 Completion of these modifications will be reviewed during a future inspectio Post-Accident Sampling (II.B.3.2.B-Plant Modifications)
The licensee is installing a post-accident sampling system which appears to meet the requirements of this ite The licensee stated that several design problems need correcting and that a letter was sent to NRR revising the expected completion date to April 30, 1982.* The installation of this system will be reviewed during a future inspectio Noble Gas Effluent Monitor (II.F.1.1.B.2)
The licensee has apparently experienced several delivery delay The system is currently scheduled for delivery on January 20, 198 The licensee stated that a letter to NRR revised the expected completion date for this item to April 30, 198 The installation of this monitor will be reviewed during a future inspectio Iodine/Particulate Sampling (II.F.1.2.B.2)
This equipment is part of the licensee's high range noble gas monito The same vendor delivery problems appl The install-ation of this equipment will be reviewed during a future inspectio Containment High Range Monitors (II.F.1.2)
The licensee has installed the required monitors with the excep-tion of one cable which was not long enoug At the time of this inspection the monitors were expected to be in use by January 1, 198 It was later learned that implementation of this item had been delayed until April 30, 1982, according to an extention re-quest to NRR dated November 20, 198 The completed installa-tion and calibration of these monitors will be reviewed during a future inspectio Improved Inplant Iodine Instrumentation (III.D.3.3.l and 2)
The licensee has the necessary materials and instrumentation available to determine airborne radioactive iodine concentrations in vital plant area The licensee has met the requirements of this ite.
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1 Allegation Concerning Radiation Work Permit Initialling On October 8, 1981, an individual alleged that radiation work permits (RWP's) were being initialled by someone other than the persons liste Licensee procedure HP 2.16 states that all persons listed on the RWP should place their initials next to their nam This is done to indicate each person understands the RWP requirement The licensee's management investigated this matter and determined that the allegation was true. It was determined that a contractor group was responsible; no licensee personnel were involve The licensee sent a letter to the contractor asking that the practice be stoppe The contractor responded by retraining their workers in RWP procedure No further instances of this nature have occurre The inspector reviewed the licensee's action No problems were note.
Exit Meeting The inspectors summarized the scope and findings of this inspection during a telephone conversation with licensee representatives (denoted in Section 1) on December 16, 198 In response to certain items discussed by the' inspector, the licensee: Stated that increased sampling of the service air system will be conducted (Section 6). Stated that 'further evaluations to determine the extent of con-tamination spread by the cooling tower overflow would be conducted (Section 8). Stated that a revised schedule for completion of Health Physics Appraisal findings would be submitted to NRG Region III (Section 11). Acknowledged the inspector's comments and concerns regarding the conduct of indoctrination training, but offered no corrective actions (Section 9).
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