IR 05000255/1988006
| ML18052B501 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/04/1988 |
| From: | Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052B500 | List: |
| References | |
| 50-255-88-06, 50-255-88-6, NUDOCS 8802110286 | |
| Download: ML18052B501 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/88006(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
January 12-15, 1988 I~
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I. /C)"-<-,,U Inspector:
C. F. Gill Accompanying Inspector:
M. A. Kunowski
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Approved By:
L. R. Greger, Chief Facilities Radiation Protection Section Inspection Summary License No. DPR-20 a-~-es Date Inspection on January 12-15, 1988 (Report No. 50-255/88006(DRSS))
Areas Inspected:
Routine, unannounced inspection of the radiation protection program during a maintenance outage including:
organization and management controls; changes in organization, personnel, facilities, equipment, and procedures; planning and preparation; training and qualifications of new personnel; internal and external exposure control; control of radioactive materials and contamination; the ALARA program; audits and appraisals; and open item Results:
No violations or deviations were identifie PDR 1~DDCI<.
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- DETAILS Persons Contacted
- D. Andersen, Senior Quality Assurance (QA) Consultant
- C. Axtell, Health Physics Superintendent
- W. Beckman, Radiological Services Manager
- E. Boque, Radiological Safety Supervisor N. Campbell, Senior Health Physicist M. Dickson, Radiological Safety Supervisor G. Ellis, Radiological Safety Supervisor R. English, Corporate Health Physicist
- J. Hadl, QA Consultant
- D. Hoffman, Plant General Manager
- L. Kenaga, Staff Health Physicist
- C. Kozup, Technical Engineer K. Krueger, Senior Engineer, NSSS
- J. Lewis, Technical Director G. Li st, Engineering Supervisor, NSSS M. Mennucci, Radiological Safety Supervisor
- T. Neal, Radiological Materials Control (RMC) Administrator
- G. Slade, Executive Director, NAD
- E. Swanson, NRC Senior Resident Inspector N. Williamsen, NRC Resident Inspector The inspectors also contacted other licensee employees including radiation protection technicians and members of the engineering staf *Denotes those present at the exit meeting on January 15, 1988. General This inspection, which began at approximately 1:00 p.m. on January 12, 1988, was conducted to review the radiation protection program during a maintenance outage, including organization and management controls, planning and preparation, qualifications and training, internal and external exposure controls, ALARA program, control of radioactive material and contamination, audits and appraisals, and open item During plant tours, no significant access control, posting, or procedure adherence problems were identified; housekeeping was adequat Licensee Actions on Previous Inspection Findings (IP 92701)
(Closed) Unresolved Item (255/87030-04):
Obtain approval of the manifest form for radioactive waste shipments to the US Ecology disposal facility in Richland, Washingto By letter dated November 24, 1987, US Ecology informed the licensee that effective January 1, 1988, a revised manifest form will be required for shipments of low-level radioactive waste received at US Ecology disposal facilities in
- Beatty, Nevada and Richland, Washingto The licensee stated that future shipments to these facilities would use the approved manifest form This matter is considered close Organizations and Management Controls (IP 83522)
The inspectors reviewed the licensee's organization and management controls for the Radiation Protection Program including the organizational structure and staffing, staff stability, effectiveness of procedures and other management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse Currently, 24 of the 25 station Radiation Protection Technician (RPT)
positions are filled; one RPT recently resigned because of personal reason There are 14 Senior Technicians, four Technician II's, three Technician I's, and three Technician Trainee About 28% of the RPT positions are either vacant or filled with personnel who have less than two years of applicable experience and do not meet the selection criteria stated in ANSI 18.1-1971 for technicians in responsible position Although the overall RPT experience level has improved notably during the last two years further improvement is desirabl The licensee does not presently intend to continue augmenting the staff with contract RPTs after the current outage; inspector concerns regarding this policy are discussed in Inspection Reports No. 50-255/86002, No. 50-255/86012, No. 50-255/87002, and No. 50-255/8703 The three Technician Trainees will not be available during the March 1988 spent fuel pool rerack project due to an offsite training commitmen The licensee indicates they will augment the staff with contract RPTs during that time perio Recent management involvement in radiation protection is discussed in Inspection Report No. 50-255/8703 No violations or deviations were identifie.
Changes (IP 83729)
The inspectors reviewed changes in organizational, personnel, facilities, equipment, programs, and procedures that could affect the outage radiation protection progra During this outage, the station RPTs and crewleaders are providing continuous coverage, seven days per week, by working twelve-hour days, five days per wee The Health Physics Superintendent and a Radiological Safety Supervisor are splitting the Duty Health Physicist function; during off-duty hours, the designated Duty HP remains on-cal Evidence of
- contract RPT oversight is exhibited by the licensee's policy of appointing station RPTs as crewleaders, with the exception of one contract RPT crewleade This scheme, combined with tours by Radiological Safety Supervisors, health physicists, and the ALARA coordinator,-appe.ars to provide adequate oversight of contact RPT activitie *
These changes appear to benefit the licensee's outage radiation protection program by providing the needed radiation protection coverage on all shifts and better oversight of contractor activitie No violations or deviations were identifie.
Planning Preparation (IP 83729)
The inspectors reviewed the outage planning and preparation performed by the licensee, including:
additional staffing, special training, increased equipment supplies, and job related health physics consideration During the outage, the station's radiation protection group has been augmented with 40 contract RPTs consisting of 35 senior and five junior technician All but six of the contact RPTs were also employed by the licensee during the fall outage; the high rate of returnees and high pertentage of senior RPTs appear to be indicative of a reli~ble contact RPT staf The inspectors verified that those technicians not meeting ANSI 18.1-1971 selection criteria were not providing radiation protection duties without proper supervisio The effectiveness of the outage radiation protection program was also enhanced by contract workers who provided decontamination, laundry, and respirator cleaning service Preoutage special training provided to station and contract workers includes mock-up training for certain high exposure work, ALARA briefings for each work group, and RWP program trainin The inspectors toured the steam generator mock-up training facility and discussed the training program with the ALARA Coordinato No problems were noted in this are The supplies of portable survey instruments, portable ventilation equipment, respiratory protection equipment, and protective clothing appear adequate for the outag Evidence that job planning and preparation is influenced by radiation protection includes containment decontamination and shielding prior to allowing outage work to begin, and radiation protection and ALARA participation in all planning and outage meeting No violations or deviations were identifie.
Training and Qualifications of New Personnel (IP 83729)
The inspectors reviewed the education and experience qualifications of contract radiation protection personnel and training provided to the Licensee selection of contract Radiation Protection Technicians includes review of the technicians' resumes to determine conformance to ANSI 18.1-1971 criteria for responsible technician Resumes of selected contract Radiation Protection Technicians who have worked at the station during the current outage were reviewed by the inspector The majority of technicians appear to meet or exceed the technician selection criteria
- in ANSI 18.1-197 Those not meeting ANSI 18.1-1971 selection criteria appear to have training and experience commensurate with their assigned duties; the licensee met their goal of 85% of the contract technicians meeting ANSI 18.1-1971 criteri After selected technicians arrive on-site they are required to complete general employee and site specific training, three days of radiation protection procedures training, and on-the-job task training and practical factors evaluation Following the procedures training, each contracted technician must pass a 50-question written examination on radiation protection procedures and policies and practical problem solving; a score of 70% is require The majority of the examination questions related to station procedure and policies; problem solving questions are limited but appeared to be moderately difficul Inspectors selectively reviewed lesson plans, training modules, the 40 procedures selected for the reading list, and training and exam records; no problems were note No violations or deviations were identifie.
External Exposure Control (IP 83729 and 83524)
The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including changes in program to meet outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification Exposure records of plant and contractor personnel for the first three quarters of 1987 were selectively reviewe No exposures greater than 10 CFR 20.101 or the station quarterly administrative limit of 1.1 rem were note The highest individual whole-body doses for first quarter, second quarter, third quarter, and first three quarters cumulative for 1987 were 1.020, 1.065, 0.793, and 1.502 rem, respectivel The total assigned whole-body dose for the first three quarters of 1987, based almost exclusively on primary TLD results, was 115.593 person-rem; the "corrected" direct-reading-dosimeter (ORD) reported dose for this same period time was 131.602 rem, perhaps indicating that the ORD correction factor is too conservativ Adding the fourth quarter
"corrected" ORD total whole-body dose to that formally assigned for the first three quarters of 1987 indicates a total for 1987 of approximately 400 person-rem; the 1987 goal was 425 person-re A computer printout of worker doses is generated on a daily basis during routine operations and updated every shift during outages; a health physicist reviews these dose printout The licensee's Management Information Dose Tracking System (MIS) is capable of recording entry authorizations and dose for all personnel entering the RC The MIS software was recently improved to permit tracking and trending of exposure informatio No violations or deviations were identified.
- Internal Exposure Control (83729 and 83525)
The inspectors reviewed the licensee 1s internal exposure control and assessment programs, including:
changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification Whole body counting (WBC) data, respiratory protection records, and air activity surveys for 1987 were selectively reviewed; no problems were note A review of licensee WBC data indicates that in 1987 only one person received a maximum permissible organ burden (MPOB) greater than 10%,
while three persons received greater than 1% MPOB but less than 10%
MPOB; these intakes are discussed in Section 7 of Inspection Report No. 50-255/8703 A summary of the 1985 and 1986 MPOB WBC data is presented in Section 9 of Inspection Report No. 50-255/8700 No violations or deviations were identifie.
Control of Radioactive Materials and Contamination (IP 83729 and 83526)
The inspectors reviewed the licensee 1 s program for control of radioactive materials and contamination, including adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness 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 inspectors selectively reviewed records of routine and special radiation and contamination surveys conducted during the outage to dat All surveys, routine and special, are reviewed by the duty HP for completeness and any unusual condition No problems were identifie Recent audits and surveillances of the radiation protection program indicate recurrences of poor frisking practices, declining housekeeping, failure to adhere to RWP requirements, and poor radiation worker practice Management involvement in correcting these problems is evident but thus far relatively ineffectiv Past programmatic problems associated with the licensee 1 s whole-body frisking policy are discussed in Inspection Reports No. 50-255/87005 and No. 50-255/87030; the licensee is considering various options to improve performance in this are Inspector observations of radiation worker adherence to procedural requirements are discussed in Section 1 *
A 1987 station goal was to reduce the percent of auxiliary building floor area contamination from 38% (in December 1986) to 22%; however, the effort has not been very effective in that a low of 37% was achieved in May 1987, a high of 48% in October 1987, and 46% in December 198 The goal for 1988 is an auxiliary building floor area contamination of 25%;
the level of effort and management involvement will need to increase significantly for this goal to be attainabl The failure to meet the auxiliary building decontamination goal appears to represent a management weakness and may be a contributing factor regarding recurrent personnel contamination problem The 1987 station goal for personnel contamination events (PCEs) was 200; the total for 1987 was 284 PCEs (214 clothing, 61 skin, and 9 both skin and clothing).
The efforts to achieve this goal included monthly QA personnel contamination surveillances and large area masslin mop smears of areas which had been found clean by small area conventional smears; if the large area smears discovered contamination, the area was decontaminate Although the number of PCEs per 1000 RCA entries fluctuate significantly from month to month depending on specific work activities, the general trend appears to be down; *a linear fit to the data indicates a reduction from 5.5 PCE/1000 entries in January 1987 to about 3 PCE/1000 entries in December 198 However, the validity of the linear curve fit may be in doubt in that some monthly data differed from the linear curve fit value by as much as a factor of tw The 1987 linear curve fit also indicates that normalized (per 1000 entries) clothing contamination decreased only slightly, normalized skin contamination increased significantly, and normalized shoe contaminations decreased significantl The licensee believes that the decreasing shoe contaminations are due mostly to the decontamination policy based on large area masslin smears and the increasing skin contaminations are partly due to increased work activities during the October 1987 outage ahd the current steam generator outag The skin contaminations are of considerable licensee concern because of the possibility of significant skin dose and the increased probability of ingestio The 1988 station goal is 350 PCEs; the goal was increased for 1988 to account for increased work activities including the completion of the current steam generator outage, the March spent fuel pool rerack project, and the 75-day fall refueling outage and to account for the anticipated increase in detected PCEs when the three purchased state-of-the-art personnel monitors become operationa The licensee plans to continue the monthly QA personnel contamination surveillances to aid in the PCE minimization effor No violations or deviations were identified by the inspector.
Maintaining Occupational Exposures ALARA (IP 83729 and 83528)
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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 outage; and 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 programmatic weaknesse The professional ALARA staff, the job history files, and the Radiological Work Practices Manual are discussed in Section 11 of Inspection Report No. 50-255/8703 The inspectors reviewed documentation relating to ALARA planning for the outage, detailed estimations of doses expected from the current outage and for the rest of 1988, and estimations of actual doses received during current outage tasks compared to doses received during previous similar task Review of this documentation and discussion with ALARA personnel indicate that the station ALARA program is effective and continues to improve performance, and that significant dose-savings may be attributed to those effort Among the special ALARA projects during this outage is the effort to remove significant hot spots by use of hydrolasing techniques; this includes hydrolasing various floor drainage system One example of the effect this project has had on the station is removal of hot spots in drain lines located outside the rad/chem laboratory area on the 611-foot elevation of the auxiliary buildin The hot spots required several inches of lead to reduce the radiation background to a level acceptable for radioactive sample counting purposes; the hot spots were removed by hydrolasing the floor drainage systems from the track alley area and the cask wash-down pi The progress made in the removal of a hot spot of greater than 1000 R/hr from the drainage system which passes through the spent fuel pool heat exchanger room is discussed in Section 1 Also, during review of work on the LPSI pump, the NRC resident inspectors identified that a change in the method of removal of a hot spot in the drainline had occurred but the ALARA plan had not been revised and workers had not received a supplemental briefin This matter will be reviewed further during a future inspectio (Open Item No. 255/87032-0l(DRP))
The 1987 total whole-body dose is estimated to be about 400 person-rem (see Section 8); the 1987 goal was 425 person-re The 1988 goal is 550 person-rem; a review of detailed task projected doses and discussions with the ALARA Coordinator indicate that this goal is consistent with the work activities planne No violations or deviations were identifie.
Hot Spot in Spent Fuel Pool Heat Exchanger Room (IP 83729 and 83528)
As part of the outage, the licensee drained and cleaned the south tilt pit (adjacent to the spent fuel pool).
The south tilt pit is a water-filled cavity in which fuel is manipulated before transfer to and after transfer from the reactor refueling cavit The pit measures approximately 21-feet long by 5-feet across by 37-feet deep and is separated from the main pool by a 4-foot thick concrete wall. _Fuel is transferred between the pit and the pool through a dam block (gate) in the wal Subsequent to the cleaning, the licensee began to hydrolase a
drain-recirculation line for the tilt pi This li~e is connected to a header in the spent fuel pool heat exchanger roo Lines from the reactor tilt pit and the safety injection and refueling water tank are also connected to this heade Subsequent to hydrolasing, an RP technician entered the room to survey the heade The survey indicated localized radiation levels on the header exceeding 1000 R/h (The Eberline Model 6112 Teletector used by the technician has a maximum scale reading of 1000 R/hr.)
According to the licensee, the technician immediately left the area when the meter went off-scal The technician 1 s dosimetry indicated that his quarterly administrative dose limit had not been exceede As of January 15, 1988, the licensee installed a ten-micron filter and a pump to drain and filter the contents of the header; the drainage is scheduled to take place in conjunction with efforts to move the hot spot by further hydrolasin Because of the high dose rates involved in this job and because the job was not completed at the conclusion of the inspection, ALARA preplanning considerations, exposures, surveys, RWPs, and operational and maintenance procedures related to the job will be reviewed further during a future inspectio (Open Item No. 255/88006-01)
1 Tours and Independent Measurements (IP 83729)
During tours of the turbine, auxiliary, and containment buildings and of outdoor storage areas, radioactive material controls, access control, postings, and housekeeping, in general, appeared adequat Inspector observations of egress activities at the main access control point indicated that workers were adhering to frisking requirement Observations of work activities in the auxiliary and containment buildings indicated worker adherence to RWP and procedure requirement Queries by the inspectors of contractors and plant personnel indicated general knowledge of pertinent RWP and procedural requirement For several high radiation areas in the auxiliary building and in containment with general area exposure levels in excess of 1000 mR/hr, the inspectors verified that doors to those areas were locked as required by Technical Specification 6.1 In addition, one of the inspectors observed remote radiation monitoring and visual surveillance of the spent fuel pool heat exchanger room (see Section 12).
The inspectors also performed radiation surveys of equipment and selected areas in the auxiliary and turbine buildings and outdoors; survey results were consistent with licensee posted results or indicated radiation levels below which posting is require A survey of anti-contamination clothing (anti-C 1 s) stored in the change-out room indicated contamination l~vels well below the maximum level allowed on useable anti-C 1 s by the
- license During a tour of the spent fuel pool operating floor with the RP technician assigned to that area and to the containment, one of the inspectors found several unmarked bags of equipment located with several marked bag The licensee uses clear, yellow plastic bags to store contaminated (or potentially contaminated) materia According to the technician, all bags
- of equipment in the area should have been marked with the bag contact dose rate and the amount of removable contamination on the enclosed equipmen The technician added that because this, information was not marked on the bags, a technician would have to don protective clothing and a respirator, and open the bags to smear the equipment; contact dose rate values could be obtained without opening the bag The Health Physics Superintendent stated that plant procedures do not require that bags of potentially contaminated equipment be marked as long as the bags are marked before leaving the spent fuel pool operating floor are He stated that the bags and the contents were surveyed before the bags were removed from the are The inspectors noted that marking the dose rate and contamination level information on the bags immediately after placing the equipment in the bags will reduce the need to reopen the bags and the use of respirators, in line with objectives stated in the licensee's 'procedures, HP 2.21,
"Contamination Control," and AP 7.02, "ALARA Program."
No violations or deviations were identifie.
Audits and Appraisals (IP 83522)
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 station's QA annual audit of the radiation protection program for 1987 and selected recent QA surveillance report The inspectors also discussed the planned 1988 QA radiation protection audit and surveillance program with appropriate QA personne The licensee intends to continue the monthly surveillances which concentrate on personnel contamination, radiation worker practices, and RWP compliance; QA observations of past poor performance in these areas are discussed in Section 1 The QA audit and surveillance program appears adequate to assess the radiation protection progra The 1987 QA audit of the radiation protection program, conducted on November 2-6, 1987, resulted in no findings and three observations, two of the observations were considered conditions adverse to quality that required actio The observations included personnel failing to log out of the RCA on the MIS dose control system and inadequacies in the MPC-hour tracking proces The auditors also noted that the newly initiated formal ALARA suggestion plan was not yet effective at the worker level, there were five Radiological Incident Reports (RIRs)
since January 1987 involving lR/hr doors which had been found open and unguarded, poor whole-body frisking practices, poor radiological work practices, and a discrepancy between the technical specification exposure record retention requirements and plant procedural requirement The auditors found that corrective actions had not been completed tor the 1986 radiation protection audit regarding one finding (inadequate bousekeeping) and one observation (missing respiratory medical certification records).
The inspectors discussed proposed corrective actions regarding auditor concerns with QA and radiation protection
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personnel; no significant problems were note The inspectors will review licensee performance in the above areas further during future inspections to monitor the effectiveness of the licensee'~ corrective action (Open Item No. 255/88006-02)
No violations or deviations were identified by the inspector.
Spent Fuel Pool Seepage (IP 92705)
The licensee postulates that high spent fuel pool {SFP) water level results in seepage through the south SFP wall at the 628-foot elevatio Based on licensee observations, leakage seems to occur whenever the SFP water level is above the skimmer box design water leve No seepage has been detected in recent months during which the licensee has made a concerted effort to keep the water level below the skimmer boxes; a
_portable purification unit has been used to temporarily replace the function of the skimmer syste The licensee has completed an initial engineering evaluation of the proble It is currently-believed that the most likely leak path originates at one or more of the skimmer boxes, migrates along the outside of the piping buried in the SFP wall, enhanced by the capillary effect of the felt-jacketed piping insulation down to the 628-foot elevation where it seeps through the SFP wall into the adjacent auxiliary building stairway and hatchwa The licensee is considered making a physical examination of the rebar located near the outside SFP wall surface, where seepage has occurred, by removing a concrete coupon using an ultra high pressure abra~ive jet. The licensee stated that the seepage passes through the floor drain to the radwaste treatment syste The licensee also stated that the station does not have a history of SFP liner leakage and that should such leakage occur, the SFP leak detection and drainage system would discharge the leakage to the radwaste treatment syste.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on January 15, 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