IR 05000255/1986012
| ML18052A613 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/18/1986 |
| From: | Gill C, Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052A612 | List: |
| References | |
| 50-255-86-12, IEIN-85-085, IEIN-85-85, IEIN-86-022, IEIN-86-22, NUDOCS 8607290022 | |
| Download: ML18052A613 (13) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/86012(DRSS)
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:
June 16-20, 1986 Inspectors:
Approved By:
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~ *!JIJ C. F. Gill
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W. B. Grant L.~
Facilities Radiation Protection Section Inspection Summary Inspection on June 16-20, 1986 (Report No. 50-255/86012(DRSS))
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7-/8-8-b Date-7-18-8~
Date Areas Inspected:
Routine, unannounced inspection of the radiation protection program including:
organization and management controls, internal and external exposure controls, control of radioactive materials and contamination, training and qualification, audits and appraisals, solid radwaste, transportation, and the ALARA progra Also, HVAC filter housing drain systems, the decontamination program, IE Information Notice No. 86-22, termination dose records, and open items were reviewe Results:
No violations or deviations were identified.
8607290022 860718 PDR ADOCK 05000255 G
DETAILS Persons Contacted D. Andersen, Lead QA Auditor
- C. Axtell, Health Physics Superintendent
- W. Beckman, Radiological Services Manager E. Boque, Radiation Safety Supervisor J. Bradshaw, Property Protection Operations Supervisor
- N. Campbell, Senior Health Physicist R. Fenech, Technical Engineer J. Firlet, Plant Manager
- D. Fitzgibbon, Licensing Engineer
- L. Kenaga, Staff Health Physicist B. Krautblatt, General Engineer D. Malone, Licensing Engineer
- D. Malone, ALARA Coordinator
- R. McCaleb, QA Director T. Neal, RMC Administrator D. Parker, Dosimetry Supervisor
- E. Swanson, NRC Senior Resident Inspector The inspectors also contacted other licensee employees including radiation protection technicians and members of the engineering and maintenance staff *Denotes those present at the exit meeting on June 20, 1986. General This inspection, which began at 2:00 p.m. on June 16, 1986, was conducted to review the operational radiation protection and radwaste programs, including organization and management controls, internal and external exposure controls, control of radioactive materials and contamination, training and qualification, audits and appraisals, solid radwaste, and the ALARA progra Also, HVAC filter housing drain systems, the decon-tamination program, IE Information Notice No. 86-22, termination dose records, and open items were reviewe During plant tours, no significant access control, posting, or survey problems were identifie Although housekeeping was poor on the first day of the inspection period, it was significantly improved by the end of the inspection perio Licensee Actions on Previous Inspection Findings (Open) Open Item (255/85010-01):
Technical specification change request concerning the organization position of the Radiation Protection Manager (RPM).
This item remains open pending NRR resolutio *
(Open) Open Item (255/85019-01):
Take steps to prevent future flooding of the south radwaste building as a result of cooling tower overflow event The licensee has completed the engineering stud Cost estimation and recommendation of the modification option are scheduled for completion by October 1, 198 (Closed) Open Item (255/86002-01):
Reduce auxiliary building contaminated area The licensee assigned this activity to a special task force which has significantly reduced auxiliary building contaminated area (See Section 9.)
(Closed) Open Item (255/86002-02):
Implement corrective actions for procedural violations concerning January 21, 1986 entry into Room 23 The inspectors reviewed the corrective actions which included additional training requirements for radiation protection technicians (RPTs) and general employees; no problems were note (Closed) Open Item (255/86002-03):
Implement corrective actions for problems identified regarding January 21, 1986 entry into Room 23 The inspectors reviewed the corrective actions which included additional RPT and general employee training, procedural revisions, and modifications of access control log in/out computer generated instructions; no problems were note (Closed) Violation (255/86002-04):
Failure to provide adequate radiation protection coverag Licensee corrective actions outlined in the licensee 1 s response dated April 11, 1986, were reviewed; no problems were note.
Organization and Management Controls The inspectors reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including the organiza-tional structure and staffing, staff stability, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, effectiveness of audits of these programs, communication to employees, and documentation of organization and management control program Radiation protection staff stability is improvin All 25 station radiation protection technician (RPT) positions are fille There are 13 senior technicians, three technician !Is, four technician Is, and five technician trainee The eight RPTs who were hired between August and December 1985, have all passed the licensee 1 s seven-week health physics course; six have bachelor degrees; and one was a contractor RPT for three years before joining the licensee's staf The other 17 RPTs have been employed as RPTs by the licensee for an average of approximately five year Three contract RPJs are currently augmenting the radiation protection staff until th~ licensee 1 s recently hired RPTs obtain more experienc According to licensee personnel, these new employees are given duties commensurate with their experience, training, and qualifica-tion Management appears adequately supportive of the human resources requirements of the radiation protection progra *
The licensee has developed a Radiological Work Practice Manua The manual provides acceptable methods and techniques for the radiologically safe performance of certain task The manual topics currently included are:
maintenance work practices, radiation safety work practices, contamination control work practices, chemistry work practices, operations work practices, and miscellaneous work practice The inspectors reviewed the Radiological Work Practice Manual; no problems were note No violations or deviations were identifie.
Training and Qualifications The inspectors reviewed the training and qualifications aspects of the licensee 1 s radiation protection, radwaste, and transportation programs, including:
changes in responsibilities, policies, goals, programs, and methods; qualifications of newly hired or promoted radiation protection personnel; and provision of appropriate radiation protection, radwaste, and transportation training for station personne Also reviewed were manage-ment techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse The licensee has recently implemented a new Radiation Safety Technician training program that they expect to be INPO accredited in the near futur The training program combines formal classroom courses, laboratory sessions, on-the-job training, and a qualification evaluation by task for some 15 radiation safety task Training is to be conducted at the licensee 1 s Midland Training Center, Palisades Training Section, and at the Palisades Nuclear Plan The training includes Palisades plant systems, fundamentals of chemistry and radiological protection technology, Health Physics I and II, radioactive material control, facility and procedure changes, technical and regulatory changes, and industry and plant operating experienc Waivers of training are permitted for previous training and qualificatio The inspectors selectively reviewed the training manual, training records and Health Physics Procedure No. HP 1.1, Revision 5, Radiation Safety Technician On-The-Job Training; no problems were note Operation of the ultrasonic cleaner used for tool and equipment decontami-nation and the Freon tool decontamination unit were turned over to the Mechanical Engineering and Maintenance Department on May 2, 198 Initial training in the operation of the units was provided by the Radiological Services Departmen No problems have been identifie No violations or deviations were identifie.
External Exposure Control and Personal Dosimetry The inspectors reviewed the licensee 1 s external exposure control and personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports,
and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse Exposure records of plant and contractor personnel for 1986 to date were selectively reviewe No exposures greater than 10 CFR 20.101 were note Total exposure for 1985 as recorded by primary TLD 1 s was about 477 person-rem Exposures for the 1985/1986 refueling/maintenance outage were about 650 person-rem Exposures for the first quarter of 1986 are about 410 person-re A computer printout of work doses is generated on a daily basis during routine operations and updated every shift during outage A health physicist reviews these dose printouts and investigates exposures when either the primary or the secondary dosimeter are above 250 mrem and differ by greater than 25%.
After the investigation has been conducted a discrepancy report is written, a dose assessment is made, and an appropriate dose is assigne The licensee 1 s Management Information Dose Tracking System (MIS) was implemented in 198 The original MIS required people entering the radiation controlled area (RCA) to get authorization by entering their social security number, RWP number, and self reading dosimeter (SRO)
reading into the MIS compute If correctly done, entry was authorized and the administrative dose remaining for that person was displaye The original MIS computer system could not authorize or automatically track individuals on a 250-mrem limit (without any exposure history) or on dose alert (approaching administrative dose limits).
Therefore individuals were authorized and their dose was tracked and controlled using Dose Control Card As of April 2, 1986, due to computer software improvements, the MIS system is capable of documenting and tracking entry authorizations and dose for all personnel entering the RC No violations or deviations were identifie.
Internal Exposure Control and Assessment The inspectors reviewed the licensee 1 s internal exposure control and assessment programs, including:
changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for main-tenance and refueling tasks including ALARA considerations; required records, reports, and notifications, and effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction program implementation weaknesse Whole body counting data, respiratory protection records, MPC-hour determinations, and air sample data from January 1986 to date were selectively reviewed; no problems were noted.
- Licensee whole body count action levels are 150 nanocuries for Co-58 and 25 nanocuries each for Co-60 and Cs-13 Plant personnel are routinely whole body counted (WBC) semiannuall If the WBC sum of fractions of the action levels is greater than or equal to one, the individual is required to shower and be counted agai If the WBC determines that the individual has an internal deposition, an investigation is made and a MPC-hour exposure is calculate No problems were note The licensee tracks individuals' MPC-hours by computer entries of RWP numbers, RCA entry time and date, and air sample dat If respirators are worn, no credit is taken for charcoal iodine adsorber A health physicist reviews air sample data for MPC-hour determinatio No problems were note No violations or deviations were identifie.
Control of Radioactive Materials and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effec-tiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated material The licensee implemented a whole body personal contamination monitoring (frisking) program in June 198 All workers exiting containment or contaminated areas are to conduct a whole body frisk at the nearest frisking statio Although QC Activity Inspection AI-85-062 dated August 15, 1985, and AI-85-075 dated October 21, 1985, record that adherence to this policy was initially poor, by the end of 1985 procedural adherence was greatly improved as documented by the licensee in QA Surveillance Report S-QP-85-31 dated December 18, 198 Likewise, although Inspection Report No. 50-255/85010, and the 1985 INPO audit report addressed failure to adhere to frisking procedures, Inspection Report No. 50-255/86002 indicates considerable improvement in this are During plant tours, the inspectors did not note any failures to adhere to the frisking polic It was, however, noted that the whole body friskers were balanced on domed trash containers in the auxiliary buildin In response to the inspectors' concern regarding the precarious positioning of these instruments, licensee representatives stated that an engineering support request had just been approved to build wall-mounted shelves to store the whole body frisker Due to an INPO commitment, licensee plans to begin daily functional checks of all survey instruments by mid-July, when the appropriate calibration sources arrive onsit The inspectors selectively reviewed records of routine and special radiation and contamination surveys conducted thus far in 198 All surveys, routine and special, are reviewed by the duty HP for completeness and any unusual condition No problems were identifie.
During plant tours the inspectors noted several conditions which may indicate a need to increase management control over radioactive material and contamination in the auxiliary building radiation controlled area (RCA), including:
(1) on June 16, 1896, portions of the general access areas of the auxiliary building were cluttered with yellow bags of contaminated material, discarded articles of protective clothing, and other objects outside designated temporary storage areas; by June 19, 1986, auxiliary building housekeeping improved significantly; (2) the inspectors observed the operator of the laundry monitor pull coveralls across the frisker in two quick jerks rather than the required steady rate of two inches per second; (3) contaminated area pasting weaknesses observed included discarded signs lying on the floor or wedged between pipes and the wall, use of radiation barrier tape to indicate localized contaminated areas, and partially obscured signs used to designate contaminated system components; and (4) on June 16, 1986, the inspectors noted that the hot tool crib was open, unattended, and workers were allowed to remove and replace tools and equipment on their own recogni-zance; the area was very cluttered with electrical equipment and returned tools left inside the contaminated area but outside the caged storage are In response to the above concerns regarding management control over radioactive material and contamination, the licensee took or agreed to take certain corrective actions, including:
(1) the person improperly using the laundry monitor was promptly reminded of the correct method, which was posted on the wall above the laundry monitor table, by the Senior Health Physicist who agreed to also remind the other operators; (2) the Senior Health Physicist also requested that the Maintenance Department cleanup the hot tool crib area and assign an attendant; subsequent plant tours confirmed that the area had been cleaned up and was operating correctly; (3) the inspectors were informed that an engineering support request had been approved to extend the hot tool crib caged storage area to include the electrical equipment lay-down area; and (4) plans exist to improve contaminated area posting when supplies, including rolls of contaminated barrier tape, arriv Although the above corrective actions are responsive to immediate problems identified by the inspectors, it appears that these examples of poor control of radioactive material and contamination may be indicative of a need for more formalized and stronger management control over the movement and storage of radioactive and contaminated tools, equipment, and other materia This matter was discussed at the exit meeting and will be reviewed further during a future inspectio (255/86012-01)
No violations or deviations were identifie Maintaining Occupational Exposure ALARA The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outages; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting the Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesse *
During the last refueling outage, the inspectors noted that the licensee had apparently learned well from past outage experience and realized significant dose savings by establishing and diligently maintaining an effective ALARA program (Inspection Report No. 50-255/86002).
The review of the ALARA program when the plant is not in a refueling outage also*
indicates that it is effectiv All five members of the ALARA group are still assigned to the program, job history files are kept up to date, pre-job briefings and post-job reviews remain effective; and it appears that plant workers have begun to take part in the ALARA process due, in part, to members of the ALARA group becoming more involved in observing jobs in progress and interviewing the workers during and just after job activitie On April 2, 1986, the ALARA goal for 1986 was increased from 400 to 500 person-rems due to unanticipated doses from an extended refueling outage and additional exposure accrued during a recent maintenance outag Each of the five major plant departments is being individually tracked to ensure that they meet their allotted portion of the remaining exposure budge The monthly goals had been met until the current maintenance outag The exposure associated with the present unscheduled outage may necessitate increasing the 1986 goal agai All reasonable effort seems to be made by the ALARA group to keep the unplanned exposures minimize In Inspection Report No. 50-255/86002, it was reported that the 1985 total dose was approximated 600 person-rems, based on preliminary data from SRDs and secondary TLD The 1985 total dose, as measured by the primary TLDs, was approximately 480 person-rem A correction factor is being applied to SRO and secondary TLD readings for 1986, therefore this year 1 s exposure estimate should be much closer to that recorded based on the primary TLD reading In order to facilitate the accomplishment of the 1986 ALARA goal of reducing the contaminated auxiliary building area from 61% to 30%, the licensee established a task force consisting of nominally 14 person The Lead Health Physicist was placed in charge of this task force, which consists of four mechanical repairmen, two temporary advanced unskilled workers, four upgraded janitors, one auxiliary operator, and three RPT This task force supplements the 16 upgraded janitors who are trained and qualified to monitor trash and laundry, perform surveys, take smears, and decontaminate area It should be noted that before 1986, only two janitors were assigned these duties and they did not receive formal training and qualification (Inspection Report No. 50-255/86002).
By the end of May 1986, the task force had reduced the auxiliary building contaminated area to 39%.
Cleanup of some contaminated areas is still hampered by a large number of minor equipment, component, and process leaks which remain unrepaired because of a large maintenance backlo A status board of which auxiliary building areas are contaminated and which are free of contamination is kept in access contro No violations or deviations were identified.
1 Audits and Appraisals The inspectors reviewed reports of audits and appraisals conducted for or by the licensee including audits required by technical specification **
Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse The inspectors reviewed the QA surveillance log for the radiation protection program for 1985 and for 1986 to date, QA annual audits for 1984 and 1985, the 1984 and 1985 INPO audit reports, and selected 1985 and 1986 QA surveillance and QC activity inspection report The inspectors also discussed the Radiological Services Department's (RSD's) response to findings and observations with the QA lead auditor and the QC lead inspector.. The audit and surveillance program appears adequate to assess the radiation protection progra A review of the selected QA and QC reports and interviews with QA and QC personnel indicate that the performance of the RSD has improved significantly during the last one and a half years in a number of key area The licensee's responses to audit findings are generally, thorough, timely, and technically soun No significant problems were noted during the selected review of audit and surveillance reports and the responses to recommendations, findings, observations, and deviation No violations or deviations were identifie.
Solid Radwaste The inspectors reviewed the licensee's solid radioactive waste management program, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; 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 The inspectors reviewed solid radwaste historical data for monthly volume generated from May 1985 through May 1986, monthly volume inventory and shipments from December 1984 through May 1986, annual volume shipped from 1972 through 198 In part, this data indicates that, except for refueling outages, less than 1000 cubic feet of solid radwaste is generated each month; most of which is compactable; the inventory has been less than 9,000 cubic feet for the last one and a half years; present inventory is approximately 1000 cubic feet; and annual shipments have reduced from a high of approximately 30,000 cubic feet in 1981 to about one-half of that amount in 1984 and 198 The inspectors toured the south radwaste building, where dry active waste (DAW) shredding, compaction, and boxing facilities are located; the storage and shipping facilities in the east radwaste; and the asphalt drumming system in the auxiliary buildin The inspectors observed the operation of the recently acquired DAW shredder and compactor, and the test for water in an asphalt filled drum containing evaporator bottoms; no radiological problems were note However, an occupational safety concern was identified concerning the operation of the shredde The licensee intends to have the plant safety officer review the matte The licensee does not attempt to segregate clean from contaminated material collected from containers marked for contaminated trash; however, each item in the containers marked for clean trash is hand friske According to licensee personnel, about half of the clean trash containers are found to contain contaminated materia The licensee records the contaminated material in a log book and is alert for correctable trend Two recent trends which were corrected are the placing of used chemistry planchets and auxiliary building floor sweepings from around contaminated equipment into containers marked for clean tras The licensee maintain a radwaste crew of three people to operate most of the radwaste facility equipment, including the shredder/compactor, waste friskers, fork lifts, bridge crane, and rigging for shield blocks and cask The crew are also assigned duties such as sorting waste, bracing shipping loads, minor building projects, and tool repai At present two of the crew members are designated as temporary advanced unskilled worker A proposal has been presented to management to formalize these tasks in new job descriptions as Radioactive Waste Specialists I and II with specific qualifications beyond that of an advanced unskilled worke Because of the importance of properly handling radwaste and preparing it for shipment, the proposed job redesignations are highly desirabl No violations or deviations were identifie.
Transportation Activities The inspectors reviewed the licensee's transportation of radioactive materials program, including:
determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification of programmatic weaknesse The inspectors reviewed selected samples of shipping papers; no problems were note The licensee has not had any negative reports from the burial site regarding their shipments since June 1983; however, there was a recent incident where the burial site failed to promptly acknowledge receipt of a waste shipmen On December 17, 1985, Radioactive Shipment No. 85-054-S left the Palisades Nuclear Plant, enroute to Richland, Washington, for burial at the U.S. Ecology Hanford Reservatio On the twentieth day after shipment, January 6, 1985, having received no acknowledgement of receipt of the waste shipment from the land disposal facility, the licensee began an investigation, per the requirements of 10 CFR 20.3ll(h)(l).
The investigation revealed that the waste shipment had been received and buried on December 30, 1985; however, the.written acknowledgement was not transmitted to the Palisades Nuclear Plant as require Subsequently, on January 13, 1986, written acknowledgement for Radioactive Shipment No. 85-054-S was received, concluding the investigatio The requirements of 10 CFR 20.31l(h)(l) and (2) are considered to be fulfilled by submission of Palisades LER 86-001-0 No violations or deviations were identifie.
Radiological Incident Reports Radiological Incident Reports (RIRs) are written for violations of 10 CFR 20 or Palisades Radiation Protection Procedure Twenty-eight RIRs have been written to date in 198 RIRs were reviewed for signifi-cance, corrective actions, and timeliness of corrective action Most reports appeared to have adequate and timely corrective actio Disciplinary action was taken on one occasion when an individual deliberately spiked his personal dosimetry; however, for several less serious radiation protection procedure violations, counselling of the offenders was considered adequate by the license Even though the number of violations is relatively small, they may be indicative of a larger proble The inspectors question whether the licensee's corrective actions are adequate to preclude recurrenc This matter was discussed at the exit meeting and will be reviewed further during a future inspection (255/86012-02).
No violations or deviations were identifie.
Decontamination Program The inspectors reviewed the licensee 1 s decontamination program, including:
decontamination techniques; qualification of personnel; and adequacy of staffing, facilities, and task priorit Most of the small decontamination tasks (such as hand tools) utilize Freon or ultrasonic cleaning equipmen This equipment is operated by the Mechanical Engineering and Maintenance Department; the training of the operators is discussed in Section Hydrolasers are available for larger task Decontamination of the auxiliary building is being directed by the Lead Health Physicist who has been assigned a special task force to augment the regular decontamination staff; the size and qualifications of the task force and decontamination staff are discussed in Section Auxiliary building decontamination techniques include hand scrubbing and steam cleanin No violations or deviations were identifie.
IE Information Notice No. 86-22 The inspectors reviewed licensee action taken in response to IE Information Notice No. 86-22, 11Underresponse of Radiation Survey Instrument to High Radiation Fields.
The licensee does not use the type of instrument described in the information notice, nor is such a purchase presently contemplate.
HVAC Filter Housing Drain Systems Several ESF and non-ESF HVAC filter housings were inspected to ascertain if the installed drain systems are configured such that filter bypass is
preclude The air cleaning systems reviewed were control room emergency makeup, fuel handling ventilation, containment ventilation, and radwaste exhaus During plant tours it was noted that all filter housing drain lines are capped except for those on the control room emergency makeup system which contain isolation valves (IVs).
These IVs are verified closed as part of the monthly fire protection surveillance program (Palisades NP Operations Checklist, Revision 26, November 25, 1985).
The installed HVAC filter housing drain lines appear adequate to preclude filter bypas No violations or deviations were identifie.
Fire Protection System Potential Leakage Problems The inspectors briefed licensee representatives on problems other nuclear power plants have had with filter damage due to fire protection system leakage, and system modifications those plants are considering to preclude recurrenc The inspectors also informed the licensee of an incident at Hatch, Unit 1 (LER 85-018-00, INPO SER 34-85, and IE Information Notice No. 85-85) where inadvertently flooded ductwork leaked water onto an Analog Transmitter Trip (ATTS) pane This introduced moisture into the ATTS panel which, in turn, resulted in the malfunction of a safety relief valve and the High Pressure Coolant Injection Syste The inspectors discussed with the licensee how several other licensees have responded to the Hatch Plant incident by design modifications, administrative procedures, and revision of fire preplan During plant tours, the inspectors noted that only the control room emergency makeup system filter housings have fire protection water deluge system Operation of these deluge systems require operators to manually connect two flexible fire hoses together and open two valves on* each syste Although the design of the installed deluge systems and the licensee's internal response to IE Information Notice No. 85-85 and INPO SER 34-85 indicate that there is little likelihood of the fire protection system inadvertently wetting the charcoal adsorbers, it appears that the licensee has not instituted administrative control beyond that needed for the initiation of the deluge system The administrative controls which the licensee is lacking, include:
(1) assurance that the filter housing will not overfill to the extent that water backs up into the ductwork, housing integrity is jeopardized, or seismic and static loading become concerns; (2) training or procedural cautions to warn the fire brigade that the water in the housing is contaminated and radwaste (or radiation protection)
personnel should be notified; (3) assurance that the housing will be drained in a timely manner without overloading the radwaste system with procedural steps to ensure that the proper isolation valves are correctly manipulated; and (4) addition of the filter housing drain line isolation valves to the valve check list of the control room ventilation system startup procedur This matter was discussed at the exit meeting and will be reviewed further during a future inspection (255/86012-03).
No violations or deviations were identifie *
1 Overexposure and Termination Exposure Reports On March 13, 1986, the Office of Nuclear Regulatory Research contacted
- NRC/Region III to report that the radiation overexposure and termination exposure reports could not be located for a diver involved in an over-exposure incident at Palisades on March 18, 1984 (Inspection Report No. 50-255/84006).
In response to a request from NRC/Region III, the licensee submitted a letter dated April 18, 1986, to the NRC Document Control Desk in Washington, This letter forwarded information, apparently previously submitted to the NRC either formally or informally, which adequately satisfies the overexposure reporting requirements of 10 CFR 20.405(a)(l) and (2) and 10 CFR 20.405(d).
As of June 20, 1986, the Office of Nuclear Regulatory Research and the licensee had not resolved missing termination records for parts of 1983 and 1984; however, it appears that the licensee was in compliance with the termination exposure reporting requirements of 10 CFR 20.408, as amended by a January 4, 1983 letter to the licensee from the NRC Executive Director for Operation No violations or deviations were identifie.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on June 20, 198 The inspectors summarized the scope and findings of the inspectio The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents/processes as proprietar In response to certain matters discussed by the inspectors, the licensee: Agreed to evaluate the apparent need for a formal policy to control the movement and storage of radioactive and contaminated tools, equipment, and other material within RCA (Section 8).
b Acknowledged the inspectors' concern regarding the adequacy of corrective actions for certain RIR (Section 13) Acknowledged the inspectors' concern regarding the adequacy of the administrative controls governing the operation of the fire protection water deluge systems for the control room ventilation systems and agreed to evaluate the matter, scheduled for completion by October 1, 198 (Section 17)
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