Text

Insp Rept 50-255/89-25 on 890814-1009.Violations Noted.Major Areas Inspected:Radwaste/Transportation Program,Including Organization & Mgt Controls,Training & Qualifications, Gaseous,Liquid & Solid Radwaste & Transportation Activities
	ML19327B279
Person / Time
Site:	Palisades
Issue date:	10/20/1989
From:	Gill C, Snell W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML19327B275	List: IR 05000255/1989025; ML19327B274; ML19327B276;
References
	50-255-89-25, IEIN-87-032, IEIN-87-32, NUDOCS 8910300062
	Download: ML19327B279 (29)
	v • d • e

{{#Wiki_filter:, , t > k9 ! U.S. NUCLEAR REGULATORY COMMISSION .i c

REGION III

'[ , > ! Report No. 50-255/89025(DRSS) ! ,. y Dorket No. 50-255 License No. DPR-20

m< Licensee: Consumors Power Compan) ! 1945 West Parnall Road i r, Jackson, MI 49201

I < Facility Name: Palisades Nuclear Generating Plant - Inspection At: Palisades Site, Covert, Michigan I f Inspection Conducted: August 14 through October 9,1989 OM XU[ /Ch0/h i ' ~1nspector: C. F. Gill Date ' i

,- r Approved By: LO. G.R8 ies/te/$f I 97 G. Snell, Chief Date- ! Radiological Controls and ! ' ~ Emergency Preparedness Section - Inspection Summary } Inspectiot on /.ocust 14 through October 9, 1989 (Report No. 50-255/89025(DRSS)) Areas Inspectet?: Routine, unannounced. inspection of the radwaste/ t transportat19n program, including: organization and management controls

(IP 83750, 84/M) training.and qualifications.(IP 83750,84750), gaseous l radwaste (JP 84750, 84724), liquid radwaste (IP 84750,84723), solid radwaste (IP 83750, 84750), transportation activities (IP 83750), audits and appraisals .(IP 83750, 84750), effluent reports (IP 84/50), effluent control instrumentation i '(IP 84750, 93702), primary coolant radiochemistry (IP 84750), air cleaning ! . . systems (IP 84750,84724), and recurrent very high radiation area entry control i incidents (93702).

< e Results: The organizctional structure, management controls, staffing levels, [ F . and upper management support for the radwaste/ transportation program appeared i generally adequate.

Four violations were identified: failure to follow

procedural requirements regarding conduction of an engineering evaluation l lacement of shielding on system components - Section 3 (Unresolved Item t before p/88021-08); failure to report an abnormal gaseous radioactive release ' No. 255 ' in the Semiannual Radioactive Effluent Release Report - Section 11; failure to ' lock doors to prevent unauthorized entry into each high radiation area in which the radiation level is greater than 1000 mR/ hour - Section 13; and failure of a

, p 8910300062 891020 PDR ADOCK 05000253 g PDC i i

_ _ _. - , , o e - radweste shipment to meet burial site requirements - Section 9.

However, ' ! because the provisions of Section V.A of Appendix C to 10 CFR Part 2 have been.

satisfied, Notices of Violation will not be issued for the first two violations.

Weaknesses were perceived in the gaseous batch release program (Section 6) and the ventilation system filter testing program (Section 14).

Additional-regulatory concerns were identified regarding the decontamination of the south .radwaste building (Section 3, Open Item No. 255/85019-01), the licensee's request pursuant to 10 CFR 20.302 for in place retention of contaminated

' soil adjacent to the south radwaste building (Section 3, Unresolved Item No. 255/86020-01), the steam generator and hotwell liquid release program L (Section 7), containment atmospheric cleanup systems (Section 14), and the need for assurance that appropriate effluent instrumentation operability ' problems are reported as required in the Semiannual Radioactive Effluent , Release Reports (Section 12).

! , l

-- +- .

y _ _ o s ,

i j

., DETAILS , ' > L 1.

Persons Contacted

- C. Axtell, Senior Staff Health Physicist M *W. Beckman, Radiological Services Manager t
- E. Bogue, Radiological Safety Supervisor
- J. Brunet, Licensing Analyst

G. Daggett, Engineering Section Supervisor f

- G. Ellis, Senior Nuclear Operations Analyst

!'

- M. Grogan, Radiation Materials Control (RMC) Supervisor J. Hanson, Operations Superintendent N*L. Kenaga, Health Physics Superintendent

' M *D. Malone, Senior Nuclear Licensing Analyst i

R. Margol, QA Administrator

' N *T. Neal, RMC Administrator , N L. Phillips, Senior Engineer R. Westerhof, Senior Engineer J. Heller, NRC Resident Inspector

E. Swanson, NRC Senior Resident Inspector The inspector alto contacted other licensee employees.
Denotes those present at the onsite interim exit meeting on August 18, 1989.

Denotes those contacted by telephone during the period August 21 through October 9, 1989.

' @ Denotes those'present at the exit meeting via telephone on October 9, j 1989.

, 2.

General

This inspection was conducted to review the radwaste/ transportation program.

The inspection included tours of the onsite facilities observation of work in progress, review of records, and discussions with licensee personnel.

l L 3.

Licensee Action on Inspection Findings LClosed)OpenItem(No. 255/85019-01): Implement actions to prevent fulure flooding of the south radwaste building (SRB) as a result of the cooling tower overflow events.

The licensee has moved the dry-active waste (DAW) process equipment from the SRB to the new addition to the east radwaste building.

At the time of the onsite inspection, the licensee still had two high radiation level contaminated filters stored in steel liners in the SRB concrete storageh nielding vaults.

Licensee representatives stated that the filters would be shipped to a radwaste burial site in the near future, the contaminated liners would be removed

. _ _ _ - , p 4 m o p i from the SRB and the rest of the SRB would be decontaminated so that the building could be released for non-radiological storage.

During plant ' , L tours, the inspector verified that the DAW process equipment had been < moved to the new addition to the east radwaste building, the SRB was decontaminated with the exception of internals of the concrete ! storage / shielding vaults, and the level of water necessary to intrude , into the vaults would need to be much higher than any historical water level due to previous cooling tower overflows (thus it appears highly unlikely that any potential future flooding of the building would spread

contamination beyond the vault internals).

This item is closed; however, the licensee's progress in decontaminating the rest of the south radwaste

' building will be reviewed further during future inspections (0 pen Item No. 255/89025-01).

l (Closed) Unresolved Item (No. 255/86020-01): Disposition of contaminated j material associated with cooling tower overflows / flooding of the south radwaste building.

By letter dated January 25, 1988, the licensee modified their November 12, 1987 request pursuant to 10 CFR 20.302 for in-place retention of contaminated soil adjacent to the south radwaste building.

The review of this revised application by NRR indicated that the request contained insufficient information for a complete NRC staff evaluation; therefore, by letter dated March 15, 1988, NRR requested additional ' information from the licensee.

By letter dated June 27, 1988, the licensee supplied the requested additional information to NRR; however, in April 1989, NRR indicated that the approach proposed by the licensee was not acceptable and issuad to the licensee a second request for additional information.

At the time of the onsite inspection, the matter was still unresolved.

Because the intent of this item was to track the licensee's initial request pursuant to 10 CFR 20.302 and the NRC response, the item is closed; however, a new item is opened to track the NRR resolution of this matter (0 pen Item No. 255/89025-02).

(Closed) Open Item (No. 255/87030-01): Review licensee's evaluation of an airborne incident in the Treated Waste Room.

The inspector reviewed the closure package for this issue dated April 11, 1989; no significant problems were noted.

ThismatterIsclosed.

(Closed) Violation (No. 255/87030-02: Failure to follow process control program and radwaste burial site requirements.

Licensee corrective actions outlined in the licensee's response dated February 4, 1980, were reviewed; no problems were noted.

, (Closed) Violation (No. 255/87030-03): Failure to follow Department of l Transportation regulations.

Licensee corrective actions outlined in the i licensce's response dated February 4, 1988, were reviewed; no problems H were noted.

L (Closed) Open Item (No. 255/88006-01): Review job history file for hot spot removal in the Spent Fuel Pool Heat Exchanger Room.

The inspector reviewed the subject job history file (No. 212); no significant problems

were noted.

This matter is closed.

l l , L

, ! l

y .. ,

! .L < ' (Closed) Open Item (No. 255/88006-02): Review corrective actions [ regardi'ng the 1987 QA Audit of the radiation protection program.

The , , inspector reviewed the closure package for this issue, dated July 24, - 1989; no significant problems were noted.

This matter is closed.

! (0 pen) Open Item (No. 255/88021-01): Licensee needs to evaluate the

apparent desirability of improving the MPC-hr determination methodology.

! The licensee initiated Commitment Tracking Record (CTR) No 89-03 on ! January ~19, 1989 (with a requested April 10, 1989 completion date) in response to the commitment to evaluate the apparent need to use ICRP-30 t methodology for determining levels of internally deposited radioactivity ' from whole body count results.

The CTR was closed by a memorandum from a

Radiological Safety Supervisor to the CTR 89-03 file, dated April 10, 1989.

The memorandum concludes that it is not appropriate to modify the

pro:edural (Procedure No. HP 8.2) methodology because the use of HP 8.2 i > would not result in significant underestimation of MPC-hours; however, ! thisprocedurewillbechangedlatertoreflectICRP-30methodolop

pursuant to proposed changes to 10 CFR 20.

Although the licensee s ! evaluation has some merit and the licensee is aware of the limitations of the current methodology, the uncertainty regarding the schedule for implementation of the proposed changes to 10 CFR 20 indicates that a reconsideration of the conclusion of the evaluation by the licensee is i desirable to preclude the potential for MPC-hour underestimation.

This matter will be reviewed further during a future inspection.

(Closed) Open Item (No. 255/88021-02): Licensee needs to evaluate the t apparent desirability of improving the location of the access control , whole-body contamination monitors.

CTR 89-04 was issued on January 19, ! .1989, to resohe this matter; the CTR was closed on August 24, 1989.

The ' l exit area outside door 1058, where the PCM-1Bs are located, is checked daily for contamination.

Year-to-date, loose contamination has only been , I found three times.

Daily and monthly checks at clean areas has reportedly

! not shown any contamination spread to clean areas.

The licensee stated l that due to space limitations and physical layout of the access control ! l~ exit area, separate egress and ingress areas are not feasible at this I time; but that HP personnel will continue to monitor the area for

' contamination. This item is closed.

(Closed) Oyen Item (No. 255/88021-03): Licensee needs to improve the

marking /laaeling of radioactive material containers / bags.

The licensee

l initiated CTR 89-05 on January 19, 1989 (with a requested June 1, 1989 ' completion date) in response to the commitment to ensure that the yellow ? h plastic bags used to store contaminated materials are properly i marked / labeled with the dose rate and contamination level to inform < personnel of the potential hazard associated with handling or unpacking the material.

The licensee issued event report No. E-PAL-88-052 on December 5, 1988, to resolve the matter; and the event report was closed on August 24, 1989.

The inspector reviewed closure package documentation and discussed the matter with appropriate licensee representatives; the ' corrective actions taken appear adequate.

This item is closed.

I e

, . ..

K f, f.1 n < , pp G7 a , c a . . .~ 'f $i.

' o, , - < ,

f.', > ^ ' p . (Closed) Open Item (No. 255/88021-04): Licensee needs to correct

. contamination control programmatic weaknesses.

The licensee has } (c successfully completed.an extensive corrective action program - p,L regarding these weaknesses (see Section 4).

This item is closed.

>'

(Closed)'Open Item (No. 255/88021-05): Licensee needs to correct an ! ' ALARA program weakrass regarding the need for source term reduction.

Personnel radiation exposure in 1988 was about 730 person-rem, which was F4 one of the higher annual doses per reactor for a U.S. PWR,. Although the ' w licensee incurred much of the exposure on unanticipated outage work and ' > on unusually extensive or one-time modification / maintenance activities, > - ;, Work planning deficiencies appear to have contributed to the high dose.

! .Also, because of initial poor p bnt system design.and previous poor operational and traintenance' activities, the plant has been plagued with L , h9. cpots.and relatively high. general area radiation fields which ' impacted the dose.

Although the licensee implemented a radiation scarce t . reduction plan three years ago, it has not been as effective as anticipated;.much additional. effort appears necessary to adequately reduce -

personn3l expos, ire.

The licensee's annual dos 9 goal for 1989 is 400 person-rem, through mid-August the licensee remained within the dose ,- , projection curve.. The licensee has recently embarked on t nore o s extensive, long term project to significantly reduce plant radiation @ 1evels'and thus fW are personnel exposure (see Section 4).

This item is

closed; .i a ( , (Closed) Violation-(No. 255/88021-06): Technical Specification 6.12.2 ' r violation (failure to provide required access control for hfgh radiation , areas'grcater than 1000 mR/ hour).

Licensee corrective actions outlined . in the licensee's response dated February 2, 1989 were' reviewed; as e ' discussed in Section 13 the corrective actions were inadequate to prevent recurrence.

This item is closed.

- (Closed) Open Item (No. 255/88021-07): Licensee needs to evaluate the apparent desirability of implementing a routine WBC Nerational check - program.

The CTR on this item was closed by'a memorandum from a ' . Radiological. Safety Supervisor to the CTR 89-08 file, dated March 30, 1969.

! ,. The merarandum indicates tnat the only check performed onsite for the two Y Helgeson WBCs is a daily background count for Co-58, Co-60, and Cs-137; ne.other performance trending information is collected onsite.

Also, a summary of quality control checks performed by Helgeson Scientific Services - is sent to the licensee every four months.

Based on past reviews of these , reports, the licensee has cencluded that ensite operational checks are , unnecessary.

However, the licensee did agree to review and trend the , f recorded background counts; which the licensee believes should provide additional confidence in the reliable operation of the Helgeson WBCs.

' 'Since CTR 89-08 was closeJ, the licensee ha3 purchased and isnplementad a new Canberra Fast Scan WBC, which has generally replaced the Helgeson i ? WBCs foi routine use.

The.'icensee stated that routine functional and h operational checks are performed on the Fast Scan WBC, including background I, checks, energy calibration checks, and efTiciency determinations.

This , _ item is closed.

l: n.l , laf

e

t l

. L'- g __ . . .

ffy ^ p y.. , '

! , ' i j (Closed) Unresolved Item (No. 255/G8021-08): Licensee needs to evaluate ! , whether an adequate engineering evaluation'was performed before shielding ' installation.- On January 6, 1988, Radiological Safety Department (RSD) ! T . personnel placed four lead blankets over the SFP tilt pit drain line located in the SFP Hx Room; this was contrary to Procedure No. HP 1.6, ! Revision 1, Control and Use of Shielding and Associated Equipment, which requires that an engineering evaluation be conducted prior to shielding l installation.

Shielding Engineering Evaluation No. 53 was completed on January 7, 1988, to verify that the shielding had been properly installed.

, Although during the inspection and at the November 22, 1988 exit meeting the inspectors discussed their concerns regarding the apparent lack of an ' adequate engineering evaluation before shielding installation, the licenses .' did not initiate a Deviation Report (No. D-FAL-89-009) to investigate the violation of HP 1.6 requirements and to implement corrective action to prevent recurrence until. January 19, 1989 (Inspection Report i 2-No-. 50-255/88021(DRSS) was isst.ed on January 3,1989).

,, The corrective action to prevent recurrence was to add to the RSD ! Continuing iraining Program a two hour' training-session regarding the . ': - circumstances surrounding this event, problems / corrective actions, and tu requirements'of Administrative Procedure No. 7.14, Control and Use of Shielding and Assaciated Equipment (which replaced Procedure No. HP 1.6).

The: inspector verified the adequacy of the training session and completion > of the corrective action by review of the training session lesson plan and personnel training records, and discussions with licensee representatives; . , no prob 1(ms were noted regarding the lesson plan and appropriate personnel { attended the training session (training was completed on March 22, 1989).

Failure to conduct an engineering evaluation prior to the placement of ! four lead blankets on the SFP tilt pit drain line on January 6, 1988, was - contrary to the requirements of Procedure No. HP 1.6 and Inus a violation of Technical Specification 6.P.1 which requires adherence to procedural < requirements.

However, pursuant to Section V.A of Appendix C to 10 CFR t .Part 2, a Notice of Violation will not be issued for the isolated Severity Level V vblation because the licensee initiated appropriate corrective t.ction upon official notification of the discrepancy when Inspection' Report No. 50 255/88021(DRSS) was issued on January 3, 1989 ~(Violation No. 255/89025-03).

'ne vioh. tion was identified; however, a Notice of Violation will not be

ssued.

, , _(Closed) Open 1 tem (No. 255/88021-09): Review changes made to allow RP . ' ! personnel to communicate with divers and review any formalization of the policy that Jivers leave the water upon detection of suit leakage.

The l"

icensee initiated CTR 89-01 on January 13, 1989 (with a requested September 1, 1989, completion oato) in response to the commitment to L

modify the underwater diving commun. cation line to allow RP per sonnel to i.

monitor conversetiens.

CT' was closed by the licensee after Radiaticn Work Plan No. 7'1 'o* .hr Radiological Work Practices Manual) f for Underwater Diving or ,cns was revised (Revision 1) on July 14,

1989.

Section III, 7.0 the revised work plan states that Health i I,

f n / yf -, i

01. / .Ill. I) i ,

-" gy i ,4 .. ..o s . Physics must have'a method available to communicate with the diver and "" the diver's assistant.

Although the work plan revision did not formalize the policy that divers are to leave the water upon detection of suit ' leakage, licensee' representatives assured the inspector that RP administrative controls would preclude a recurrence of the October 7, 1988 event (see Section 9 of Inspection Report No. 50-255/88021(DRSS)). ' This item,s closed.

, (Closed)'Open Item (No. 255/88021-10_}: Review licensee actions ' concerning apparent discrepancies among plant workers, RSD, and 1 raining Department personnel regarding the proper interpretation of dedicated RP - job coverage.

The licensee initiated CTR 89-09 on January 17, 1989

' (with a requested April 1, 1989 completion date) in response to the commitment to clarify the definition of dedicated RP job coverage.

The CTR was closed by the licensee by a memorandum from a Radiological Safety Supervisor to the CTR 89-09 filei dated March 17, 1989.

The memorandum W< discusses. the closure review and additional corrective actions taken, including the findings that (1) policy memoranda (dated September 12, F - 19t36 and August 11, 1987) and administrative documents (T/S 6.12.1.C.

Procedure No. 7.03, and Radiation Safety Plan No. 20) have correct and consistent definitions of dedicated coverage; (2) RST training lesson plan HP-SEM-01, Revision 0, Radiatior Safety Job Coverage, correctly stated the definition; (3) RST Training Lesson Plan Handout No. SH-HPI-10, Revision 0, Radiological Work Coverage, had an incorrect definition; and (4) the Palisades GET training manual does not specifically address the definition of dedicated RP job coverage.

In response to the above training deficiencies, the RS Supervisor issued (1) a memorandum requesting'the Midland Training Center to incorporate ' L the necessary change to the definition of dedicated coverage in the ' SH-HPI-10 training seminar and (2) a memorandum requesting the Palisades l l' 1 raining Department to incorporate the correct definition of dedicated i coverage into the GET program.

The inspector verified that current drafts ' of the Basic Radiation V.ker Palisades Specifics General Employee , L Training Handout (SH-GET-BRW, August 21,1989) and the RST Radiological Work Coverage Lesson Plan (No. HPI-13) with associated Training Handout

, l No. SH-HPI-13, dated October 11, 1989 and August 17, 1989, respectively) L contain corrected definitions of dedicated RP job coverage.

The licensee ' L seted that the. corrected lecson plans would be approved and implemented . - ir the near future; therefore, this matter is closed.

. (Closed)yre.1vedItem(No. 255/89018-03): On June 30, 1989, the 1R door to che Dirty Waste Drain Tank (T-60) Room was found to be unlocked and unattended in apparent violation of regulatory requirements.

This

-matter is discussed in Section 13 of this inspection report; it was ' determined that the incident represents a violation of Technical , X Specification 6.12.2.

This item is closed, , w ' (Closed) Violation (No. 255/89025-03).

Failure to follow procedurtl requirements regarding conduction of e engineering evaluallon bef;, e ' ' placement of shielding on system components.

Because the provisions of '. Section V.A of Appendix C to 10 CFR Pu t 2 have been satisfied, no Notice ' of Violation was issued; this item is closed (see Section 3, Unresolved ' Item No. 255/88021-08).

,

.c

, W * j J '.q q y ) ' ' . , _ ,

w- . - _ ,. , . M.N. . ' & k' h)> q N ? . (Closed) Violation (No.'255/89025-06): Failure of a radwaste shipment

a i ' to meet burial site requirements..The inspection showed that actions i F,' had been.taken to. correct the identified violation and to prevent i F recurrence? Our. understanding ~of the-licensee's corrective actions is l: described in Section 9'of this inspection report.

Consequently, no reply , ' to the violation is required and we have no further questions regarding ! this matter at this time.

" L (Closed) Violation-(No. 255/89025-07): Violation of Technical' Specification 6.9.3.1.A (failure to report an abnormal gaseous radioactive release in the Semiannual Radioactive Effluent Release

Report).

Because the provisions of Section V.A of Appendix.C to 10 CFR Part 2 have been satisfied, no Notice of Violation was issued; . this' item is closed (see Section 11).

(Closed) Open, Item (No. 255/89025-08): Licensee needs to revise , procedural-requirements to ensure that failures to return Technical ' g L Specification effluent' instrumentation to operable status within 30 days ' V are reported in the Semiannual Radioactive Effluent Release Reports.

! Because the licensee initiated-appropriate action before the end of the inspection (see Section 12), this matter is closed.

. (Closed) Violation (No'. 255/89025-09): Violation of Technical

Specification 6.12.2 (tailure to lock doors to prevent unauthorized entry.into each high radiation area in which the radiation level is

- greater than 1000 mR/ hour).

The incpection showed that actions had been-completed / planned-to correct the identified violation and to . . prevent recurrence.

Our understanding of the licensee's. corrective ' actions is dest bed-in Section 13 of this inspection report.

Consequently, no reply to this violation is required and we have , no further questions regarding this matter at this time.

4.

Oroanization and Management Controls (IP 83750, 84750, 83722) lhe' inspector reviewed the licensee's organization and management , controls for the radiation p"otection and radwaste/ transportation _i program, including: organizational structure; staffing; effectiveness ~ of. procedures and other management techniques used to implement the program; and e :perience concerning self-identification and correction of program impit. mentation weaknesses.

, The organization of the Radiclogical Safety Department (RSD) remains ,. about as discussed in Inspection Report No. 50-255/88021(DRSS),except I for the addition of a radiological engineer and an increase in the radwaste handler staff from seven to twelve members.

The turnover rate f for the Radiation Safety Technicians (RST) staff continued to be low with

Jh7 well qualified replacements. The Health Physics Superintendent and the ' L' Senior Staff Physicist switched positions in January 1989.

The inspector

reviewed the qualification; of the present Health Physi,cs Superintendent

l (who has been designated the Radiation Protection Manager) regarding the L RPM requirements as specified by Technical Specification 6.3.2 (meets or exceeds the' qualifications stated in Regulatory Guide 1.8, September 1975); no roblems were noted.

The training and qualifications of other RSD staff mem ers are discussed in Section 5 below.

, , '

,, ' ,y ,I: "' ~

, -- . .

&. s l 's .'- , o.

, , , , j I , , b.,1W.

Ms ,

' ' _'t' a s.

5 Management support of RP/radwaste programs has been extensive with < i h resultant: improvements in several areas, although some areas appear , t [([c to require additional. management attention.

Management initiated i improvements include a'significant reduction of personnel contamination , " events (79 PCEs through mid-August) in 1989 (compared ta 1471 PCEs in h(; 1988), by. increasi.1g the' decontamination staff which resulted.in lower , contamination levels and fewer contaminated areas, contracting an outside i

protective clothing (PC) laundry service, use of better quality PC and

hospital' scrubs under the PC, and improved radiation worker practices.

L In addition, waste gas system and liquid sampling system leakage e reduction was improved by the use of a Xenon gas sniffer, ventilation .; t, system improvements, modifications of equipment and piping, and flex , . lancing of piping to remove blockage.

The licensee also developed a j . comprehensive radiation source term reduction plan which includes - ' L proposed plans for hydrogen peroxide addition to reduce primary coolant . activity during shutdown, hot spot removal, a system chemical ,

decontamination feasibility study, primary coolant and spent fuel pool L filter upgrades, and more effective use of the letdown demineralization , ' s.vstem.- Areas that appear to warrant continued management attention ,, include support for the more extensive source reduction techniques such as system.chen.ical decontamination and cobalt inventory / replacement; ' improvement of.the gaseous batch effluent release program (see Section 6) and of the ventilation system filter testing program (sde Section 14); , and better support of the outage RP job coverage requirements than .. occurred during the 1988 fall outage.

No violations or deviations were identified.

5.

Training and Qualifications of Personnel (IP 83750, 84750, 83723) ' The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs , including: changes.in. responsibilities, policies, rograms and methods; ' . qualifications of newly-hired or promoted radiation gotection/radwaste ' "; ' personnel; and provisions for appropriate rediation protection, radwaste L , and transportation training for station personnel.

Also reviewed were management techniques used to implement these programs and experience ' concerning self-identification and correction of program implementation . weaknesses.

, i , The :rapector reviewed the training programs for RST qualification and i continuing training, NGET, basic radiation workers, and radioactive waste E handler qualification; no significant problems were notti.

The inspector also reviewed the Advanced Radiation Worker Training Program which is . part of the qualification requirements for members of the Operations

l1 Department to allow self-monitoring in designated high radiation areas (HRAs).

During a previous inspection (Inspection Report No. 50-255/88021(DRSS)), the inspectors discussed with licensee < > management the importance of maintaining adequate RSD oversight of the 'y' Advanced Radiation Worker Training Program to assure that the privilege of self-monitoring is not abused; the licensee's recent history of poor entry control for HRAs greater than 1R/ hour (see Section 13) may be - indicative of inadequate oversight of this program.

However, radiation ei

10 s.

l?,. t {, i ,, , _

' w A.

, , '.,x > ' ' _ i protection /radwaste training has improved significantly during the'past ' ' . ' L year, including establishment of an RP curriculum committee to' review

l and evalulte training effectiveness, development of a formal radwaste " > L' ' worker training and qualification program and an ALARA engineering course ' ,

specifically for design / system engineers, and introduction of an RP' summer internship program.

No violations or deviations were identified.

l 6.

Gaseous Radioactive Radwaste (IP 84750, 84724) , ' The inspector reviewed.the licensei s gaseous radwaste management program,' including: changes in equipment and procedures; gaseous , e radioactive waste effluents for compliance with regulatory requirements; ' adequacy of required records, reports, and notifications; process and ' ' effluent: monitors for compliance with maintenance, calibration, and . operational ~ requirements; and experience concerning identification and < correction of progremmatic weaknesses.

j ' The inspector reviewed the' licensee's procedural methodology regarding , the gaseous batch release permit program.

These program requirements , are specified by Procedures No. HP 6.6, Evaluation and Release of Waste t Ges Decay Tank, and No. 6.4, Containment Purge.

Although a review of - selected batcu permit records did not identify any significant problems, it was noted th".t the licensee-has a continuous containment - ' depresmrization system; in the inspector's experience, all previously '< reviewed PWR plants had batch release containment depressurization systems.

Because of the apparently unusual nature of the licensee's containment depressurization system and the potential for this mechanism representing a significant release pathway to the environs, the inspector (with-the licensee's aid) analyzed the previous gaseous radioactive ' effluent release data for Palisades; the results of that review are ' , presented.below.

. A review of historical radioactive gaseous effluent release data showed that Palisades had releases of about 3700, 173, 1778, 2431, and 44 curies in 1985, 1986, 1987', 1988, and the first half cf 1989, respectively.

' 'From May 19, 1986 to April 16, 1987, the plant was in an extended maintenance. outage; consequently gaseous.effluant releases for 1986 and the first half of 1987 reficct lower than ant:cipated gaseous radioactivity releases.

Also, since early 1987, the licenset has conducted an extensive leak reduction program for the plant's waste gas system and liquid sampling systems with good results (see Section 4).

' The percent of the radioactive gaseous effluent releases for continuous containment'depressurization, containment purge, and waste gas decay tank (WGDT) werc 78.9, 17.4, 3.7; 92.2, 5.2, 2.5; and 80.4, 5.7, 13.9 for 1987, 1988, and the first half of 1989, respectively.

Because 80-90% !

J of the gaseous radioactive effluent release from the plant is via the i

continuous containment depressurization pathway, the inspector discussed < with the licensee the apparent desirability of performing an evaluation to determire if the postulated offsite dose release savings would justify . the modification of procedures and system components to treat containment depressurization/ vents as batch releases.

This matter was disctssed at the exit meeting (see Subsection 16.d) and will be reviewed further , during a future inspection (0 pen Item No. 255/89025-04).

l < . . . . . . >

gx.

.; .< .- o [ ( 127, <* ' @3 ; { < * ' '

- k In. Inspection. Report No. 50-255/87030(DRSS), two recent events (on' June 4 ' F~ and July 8,'1987), were discussed as possible indications of minor ' , ' - programmatic problems regarding operation of the. waste gas system because . of operator. inattention to detail and failure to follow procedures; three

, x,

. additional events have occurred since that inspection'.0n October 19, . 1987, contrary to'T/S 3.24.6.1, the gaseous contents of WGDT T-101B were ' "~ I released to the atmosphere without being held.for a minimui. of 15 days.

',, 'The cause of the unauthorized WGDT release was inattention to detail and

' procedure non-compliance; 7.2 curies of noble gases were released.

On %", February 9,1988, contrary to T/S 3.24.6.1, the partial contents of WGDT d T-68C were released without being held-for a minimum of 15 days.

The WGDT lost pressure and contents due to loose valve bonnet bolts; the ," licensee ectimated that 6.032 curies of noble gases were released tu the environs before the problem was corrected. 'On December 24, 1988, approximately 14 percent'of the gaseous contents of WGDT T-68B were accidentally released to the atmosphere without being held for a minimum l ... of 15 days as required by T/S 3.24.6.1.- The cause of the unauthorized F' WGCT release was again operator inattention to detail; however, the

"' release was terminated as soon as the error was realized; only 1.16

0 mil 11 curies of Xe-133 ware released.

LERs were issued for all five ' events (87-017, 87-020, 87-036, 88-002, and 88-024).

The LERs were ' reviewed by the resident. inspectors and documented in inspection reports.

Because the above events appear to meet the criteria of 10 CFR

Part 2, Appendix C, for self-identification and correction of problems, , no Notices of Violation were issued.

i i No violations or deviations were identified by the inspector; however, i one.open item was identified.

, I 7.

Liquid Radioactive Waste (IP 84750, 84723) ' ' The inspector reviewe'd the licensee's liquid radwaste. management program, including: changes 1.n equipment and procedures; liquid radioactive waste.

j

- effluents for compliance. with regulatory requirements;: adequacy of j required records, reports, and notifications; process and effluent { monitors for compliance with maintenance, calibration, and operational < requirements; and experience concerning identification and correction of programmatic weaknesses, i Sainpling and release methods and procedures, records, and reports appear ] ,, l~ generally adequate.

The inspector selectively reviewed liquid batch i release permit records for 1987, 1988 and the first half of 1989; no l significant problems were noted.

There were 99,176, and nine liquid i radioactive effluent batch releases for 1987, 1988 and the first half of 1989, respectively; torresponding 1985 and 1986 totals were 112 and 140, yn respectively.

' $ l The inspector reviewed sur ' of liquid radioactive effluent ' , .. releases for 1985-1988 r 'm 'f of 1989.

The 1989 whole body; ! maximum organ dose tota a MW 1350% and.0497%;.0256% of the ! e l' T/S dose limits 9 the f~ nw quarter, respectively.

The 1988 whole body and t <imum is were.525% and.282% of the T/S l . .

{ ! . [ mI,,

' y L , . yy p (: ;

> Y;Y - ' ' : 10 . . . ' annual' dose limits, respectively; the correspor. ding 1987 totals were

F.f 2.43% and 1.21%, respectively.

The total liquid tritium and fission / l . ' activation products (without tritium,. gases, alpha) releases for the ' h."g first'haif~of 1989 were 38.6 curies and 2.21 E-3 curies, respectively; s ' the corresponding 1988 totals were 283 and.0355 curies, respectively; ' b.

' L ' The 'iiquid release data for 1985 and 1986 showed whole body; maximum

and the corresponding 1987 totals were 120 and. 0923 curies, respectively.

' organ dose totals of 96%;.615% and 1.32%;.500% of the T/S annual

ix dose limits, respectively.. ~ " Licensee representatives stated that most of the postulated offsite dose contributions have historically been due to the release of processed ' k, laundry water < Specifically, the onsite laundry facility processed.a , ' large number of significantly contaminated PC in 1987 which resulted in J, .somewhat elevated radioactive-liquid effluents.

During the first half of ' 1988, most of the. higher contaminated PC was processed by a vendor who did.not disc'narge waste water offsite, and during the last half of 1988, i b the~onfite-laundry facility was dismantled because all PC was processed

' ' by an offsite' vendor; therefore, the radioactive liquid releases o offsite decreased in 1988 and to an even greater extent in 1989.

Thus,

not raly did'the decision to process PC offsite contributed to the

reduction of PCEs but it also significantly reduced both the number of batch releases and the radioactive liquid effluent.

The licensee han . used the free space in the auxiliary building created by elimination of the laundry facility to greatly enhance the capability of the acce';s control facility.

On November 4,1988, there was an apparently unmonitored release from the , .B steam generator (S/G) to the lake.

During the Jrain of the B S/G to l' tank T-2 (Condensate' Storage Tank), a hotwell batch release was initiated while the makeup. valve from T-2 to the hotwell was open.

Since it initially appeared that an unmonitored release occurred through the , aforementioned pathway without a batch analysis of the S/G or continuous ! l;, monitoring, event report No. E-PAL-88-046 wu issued to investigate the

matter.

(Technical Specification Surveillance Requirement 4.24.3.1.a states that radioactive liquid wastes shall be sampled end analyzed

f acccrding to Table 4.'24-3; Table 4.24-3 requires that each batch waste release tank be sampled prior to release.) By a review of the Auxiliary . Operator (A01 logs, the Operations Department evaluation concluded that an unmonitored release did not occur. The drain of the B S/G commenced

' at 0850; however, per the secondary side A0 log, the makeup valve was manually isolated at 0340.

Although I&C worked on the valve positioner E (cycling the valve) during the hotwell batch release, no water was - transferred from T-2 to the hotwell since the vahe was manually isolated during the hotwell batch release.

US and T-2 water level logs and flow ,, rate logs also support the conclusion that T-2 was not discharging into the notwell during the batch releast j Although the evidence indicated that an unmonitored release did not occur, discussions with licensee representatives imply that may have been ' sumewhat fortuitous.

The inspector also M ted that on February 21, 23, i and 24, 1988, the secondary side contents of two S/G's were discharged to

l-l ' ' > , , , n . . ,

y- , , , . , , , , , p.

,, - , p <, , ' , , > e b' ' lthe lake without the required liquid effluent analyses; therefore, it may ! - r4 - be desirable to enhance the. procedural methodo*.ogy for S/G and hotwell 6' batch releases.

It appears that the licensee would be prudent to conduct v an evaluation of the S/G and hotwell; release program to assure that future '

$ L unmonitored releases are precluded.

This matter was discussed at the - V exit meeting and will be reviewed further during a future inspection

,

-

. (0 pen Item No. 255/89025-05).

l <, ., , ' No violations or deviations were identified by-the inspectors; however, , one open item was identified.

> 8.

Solid Radwaste (IP 83750, 84750) . . ? The inspector reviewed the licensee's solid radwaa.e management program, ' including: changes to equipment and procedures; processing, control, and storage of' solid wastes; adecuacy of required records, reports, and ' , notifications;-implementation of procedures to properly classify and characterize waste prepare manifests, and mark packages; and experience ' I concerning iaentifIcation and correction of programmatic weaknesses.

' -The inspector reviewed selected portions of the licensee's solid radwaste [ processing,. storage-and shipping records for 1985-1988 and the first half

..of 1989; no significant problems were noted.

The licensee's records 1' indicate that approximately 16,914; 8445; 7889; 6612; and 5086 cubic feet of solid radwaste were shipped in 1985, 1986, 1987, 1988, and the first ' half of 1989, respectively.

The corresponding records indicate that approximately 12,360; 6851; 6533; 9181; and 1871 cubic feet of solid radwaste were' generated in 1985, 1986, 1987, 1988, and the first half of 1989, respectively.

The pneration peak in 1988 was due to solid radwaste L produced during an extensive outage; the solid radwaste volume shipment

in 1989 is much larger than the volume generated because the licensee greatly reduced stored inventory because of the' perceived potential for ' possible closure of some burial sites.

As of August 14, 1989, the licensee's records indicated a total of approximately 1500 cubic feet of , solid radwaste was temporarily stored onsite, awaiting shipment to burial .. . sites.

The inspector reviewed radwaste generated / shipped trend charts J .. for 1988 and 1989; it was noted that the licensee sets radwas N generation

goal:; which are approximately equal to the previous year's na;ional average ! and although the goal was exceeded for 1988, the radwaste generated for 1989 remains well within the cumulative monthly goal.

It was also noted > o that the vast majority'of the radwaste generated is dry-active-waste (DAW); , , ' since December 1988, the licensee has been reducing the volume of DAW

generated by using the services of an offsite vendor who significantly l increases the compaction ratio.

The inspector toured the solid radwaste facilities incitding the storage facility and shipment stagine; area; no significant problems were noted.

The progress in decontaminating the sotth radwaste building (SRB) and the transfer of processing equipment , from SRB to the new addition to the east radwa:,te ouilding is discussed i in Section 3.

No violations or deviations were identified.

+

'~ -- -. .. . .- - . -

' - ,. , , L i % :,. < b$ , fy ,, , ,

9.

j ransportation Activities (IP'83750) j ,y, The inspector reviewed the licensee's transportation of radioactive W materials program, including: determination whether written implementing ,' D e 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 ' ' ' .g program; determination if there were any transportation incidents , involving licensee shipments; adequacy of required records, reports, i

shipment _ documentation,-and notifications; and experience concerning y . identification and correction of programmatic weaknesses.

x

The inspector selectively reviewed portions of the radweste shipment . records for 1988 and to date in 1989.

The informatien on the ship;'ng-papers appears to' satisfy NRC, DOT, and burial site recuirements.

However, significant problems were found with a Palisaces radwaste shipment upon arrival at the Barnwell waste burial facility, as described below.

, s The inspector reviewed the finding from en investigation of a radioactive ,, o ' weste' shipment _from Palisades conducted on November 28, 1988, by representatives of the Department of Health and Environmental Control, ' + State of Sout5 Carolina,'upon arrival at the Barnwell, Seuth Carolina , low-level waste burial site.

Information regarding the findings and

the licensee's subsequent corrective actions was gathered mainly from interviews with licensee representatives; letters dated December 6, 1988, and' December 23, 1988, from the State of South Carolina, Bureau of r x l ' ' Radiological Health, to the licensee; a letter dated December 13, 1988, from Chem-Nuclear' Systems, Inc. (CNSI) to the licensee; and licensee ! Deviation Report No. D-PAL-88-245.

' In September 1988, the licensee and CNSI conducted an investigation to demonstrate.that old liners, reportedly stored under less than ideal.

. ' conditions for more than ten years, could be dewatered to current burial license' criteria.

In October 1988, the liners were evaluated for containment integrity because of extensive surface rust with some pitting; > , the licensee decided to ship the containers because, even with the rust L , I and pitting, the quarter-inch steel containers were deemed aequate to meet LSA requirements and were too expensive to disgard.

On November 21, , p-1988, the' licensee dispatched exclusive use radioactive waste shipment 7 88-075'(CNSI 1188-253) to the 3arnwell, South Carolina low-level waste i burial site on'a flatbed trailer, classified as Radioactive Material, LSA, N.0.S., described as dewatered resins packaged in four steel liners ' (the aforementioned rusted and pitted containers).

On November 23, 1988, l the shipment arrived at the Barnwell site and the CNSI Licensing Manager informed the licensee's RMC Supervisor by telephone about concerns , i regarding the rusty liners, the lack of resin isotopic analysis . documentation (reportedly, the analysis documentatdon was telecopied to Barnwell by the licensee upon notification), and the lack of attached > lifting cables for offloading the liners.

On November 28, 1988, the o .CNSI Licensing Manager again called the RMC Supervisor to state that L the liners could be buried if they posted an inspection for free water.

' . t , . . -y.

- .

. c, ~ ' - s ,.,m < ' , ,

, ; F q,

, ' . t l't w , , On' December 1, 1988, the CNSI Licensing Manager informed the W ' - J' Supervisor that no free water was found.in the liners and the

containers'. integrity was adequate for burial after liner surfoce g , y

preparation.and oainting.

In a' letter dated Dncember 6, 1988, the State of South Carolina cited ' the licensee for two violations of the burial site license requirements g" because'of the problems found with Palisades radioactive waste shipment No.;1188-253 during an investigation conducted on November 28, 1988, by / ~ the S.C. Department of Health and Envirenmental Control.

The violationc were (1) the four steal liners exhibited considerable corrosiun upon . arrival at the burial facility, contrary to the requirements of 'l , Condition 61 of S.C. Radioactive Material License No. 097 and (2) upon' ' s.

~ arrival at the Barawell. facility the shipment documentation did not include an isotopic analysis for the dewatered resin, contrary to the requirements of Condition 37 of S.C. Radioactive Material Licensee 097.

' ' The<1etter further stated that it is common practice for the shipper to provide appropriate lifting. attachments, although the lack of lifting cables on the four liners was not a violation because this was not'a cask '

.,

shipment. >The licensee was assessed a civil. penalty of two thousand . dollars and notified that their Radioactive Waste. Transport Permit , No. 0006-21-88-X had been suspended until such time as the licensee ' .

demonstrates.to the satisfaction of the Department that adequate measures . . have been implemented to ensure' compliance with ell applicable provisions ! of: Federal and State law.

By letter dated' December 13, 1988, the CNSI Licensing Manager enclosed a . copy.to the licensee's:RMC Administrator of the completed site discrepancy

%., form for the subject'radwaste shipment.

Also on December 13, 1988, g DR-PAL-88-245 was prepared by the licensee.

On December 14, 1988,-the

I: RMC Administrator informed the S.C.-Bureau of Radiological Health that the. licensee did not centect the violations-and enclosed payment for

' the civil penalty.

The letter also discussed the root causes of the violations and the corrective actions, as follows: The isotopic analysis of the dewatered resin was omitted becauce

of an incomplete requireinent on the HP 6.34 shipping procedure QC checksheet which was interpreted as only being required for greater i than one microcurie /cc activity resin.

The licensee stated that-the checklist requirement has been changed to reflect the actual requirement of Condition 37 of S.C. Radioactive. Material License 097.

, The liners in question were evaluated before shipment and it was

.. determined by the licensne that the surface condition appeared to Vr meet the requirement of Conditfor 61 of S.C. Radioactive Material License 097; however, in hindsight, the licensee admitted that this T, interpretation should have been discussed with the S.C. Bureau of Radiological Health before shipment.

The licensee stated that i packaging procedure HP 6.18 will be expanded to address and discuss the Condition 61 requirements includinc package integrity, , , e corrosion / rust requirements end appearance.

(p 1S , d ' a q.

_ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _. _, _. _ _. _ _ _ _ _ _,.,., _. . -. _ ~ _ _ I

pvy z y Y ~' - ' ' . ' , .r , kk ,

j y( l '

, . . a

Because the liners'were loaded and handled by fork truck at tha e ,,

Palisades site, the licensee assumed that the CNSI Barnwell site i i . crews would use the same method; therefore, the licensee did not i ' ', , install lifting cables.

The li::ensee stated that-this requirement

"' "will be added to the' truck loading checksheet to prevent recurrence.

, ,

By. letter datee December 28, 1988, the S.C, Bureau of Radiological . - ' ' Health informed ~the licensee that the South Carolina Department of Health and Envircnmental Control was satisfied that the licensee's corrective ' . actions wiH restit in compliance with applicable provisions of the V disposal facility license;.therefore, the licensee's Radioactive haste ' . t ' Transport Permit No.' 0006-21 't8-X was reinstated effective December 22, , 1988.

The inspector verified that Deviation Report No. D-PAL-88-245' had l L. n been appropriately resolved and thr.t Procedures No. 6.18 and 6.34 had been appropriately revi' sed.

The licensee's corrective. actions appear adequate _to prevent, recurrence.

The: aforementioned failures of the licensee to comply with the Barnwell waste'buriol facility license: conditions represent a failure to adhere . , i' to Procedure No. HP'6.34,-Radioactive Material Shipments - Burial Sites Only, which requires that~a111 shipments meet burial site requirements.

Failure to adhere to Procedure No.' HP 6.34 is'a violation of Technical , Specification 6.8.1 which requires that written procedures be established, '! implemented, aM maintained (Violation No. 255/89025-06).

, , Jne violat'on was identified.

j , ' -10.

Audits and Appraisals-(IP 83750,84750) i The inspector' reviewed reports of' audits and appraisals conductet for or by the licensee includin0 audits required by Technical Specif cations.

Also reviewed wer9 management techniques used to implement and a d'r '.ne m program, and experience concerning identification and correctiv '

y p agrammatic weaknesses.

' ihe inspector selectively reviewed portions of the QA audit and ' . surveillance reports for 1988 and to date in 1989.

The licensee's QA audit / surveillance program appears adequate to assess technical e performance, compliance 'with requirements, and personnel training / } qualification relating to the radweste/ transportation program.

The , QA auditors assigned to review this functional area appear to have the necessary expertise' and experience prerequisites.

Interviews with F appropriate licensee personnel indicate that responses to audit / i y' surveillance findings cra generaily thorough, timely, and technit. ally - sound.

-. > W No violations or deviations were identified by the inspector, i c.

, / I r x ,1, , j k, . . _, _

" '

er w ,y y . . . es } Q l' " () ' , , q,1 4[{\\ . ,

9, p:p

' , e #,, ~L . EffluentReports(IP.84750,J

, . ' 111.'

p a

, The inspector selectively reviewed rad' ological ef fluent a'nalysis' result's. ' i ' to determine' accuracy of data reported in the Semiannual Radioactive , W;r ' Effluent Release Reports for 1985-1988 and,the first half of 1989.

, ,

Technical Specificction'6.9.3.1.A requires, in part, that the Semiannual

. sLX Radioactive Effluent 4elease Reporte include the identification and j quantification of' abnormal releases of. radioactive material to the environment and include a summary of radioactive gaseous effluents a-

$ specified in Appenoix:B 'to Regulatory Guide 1.21,' Revision 1 June'1974.

Section'A.6 of the aforementioned appendix specifies, in part, the !

identification and cuantification of abnormal (unplanned or uncontrolled)

, gaseous releases.

The~ inspector identified an abnormal' gaseous-radioactive ' t release which occurred on February 9, 1988 (see Section 6),'but which was-not reported by.the licensee in the Semiannual Radioactive Effluent Release Report'for the period from Januarv l'through June 30, 1988. On' October'4, .' 1989, upon: notification by the inspector, the licensee agreed that the subject event was required to have been reported, committed to correct r , the overright in' the next Semianrual Radioactive Ef fluent Release Report, h4 and promptly initiated corrective actions to prevent recurrence. The - L f;;, ' licensee will'be revising Procedure No. HP 10.5,' Palisades Semiannual Radioactive Effluent ~ Release Report, te require that the licensing events i and. deviation report logs be checked for all abnorr.a1 releases.

.; Feilure to report the February 9,1988, abnormal release is a violation of J k< Technical Specification 6.9.3.1. A; however, pursuant to ection V. A of . Appendix C to 10 CFR Part 2, a Notice of Violation will not be issued for ! "L' .this isolated Saverity Level V violation because the licensee initiated ' .

/

appropriate corret.tive action before the inspection ended'(Violation ' No..255/89025-07).

M One Violation was identified; however, a Notice of ' Violation will not be k issued, t ('- 12.. Effluent Control Ins,_ty mentation (IP 84750,9370,2J

The inspector reviewed the records for effluent control instrumentation ... E surveillance / operability, including reports to the NRC required by ! ' ' Tachnical Specifications (T/S).

[ . a.

Semiannual Radioactive Effluent _ Release Repcrts_ol,Ino_gerability i f

T/S 3.24.2.1.b, Radioactive Gastous Effluent Monitoring . ' Instrumentation Limiting Cundition for Operation, requires the 7" ' licensee, with less than the minimum number of channels operable, to excrt best, efforts to return the instrument to operable status within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not . corrected in a timely manner.

The inspector reviewed these reports , L; o for 1985-1988 and the first half of 1989; the licensee has reported . only one failure to return T/S gaseous effluent instrumentation to ! ' oprability within 30 days.

T/S 3.24.1.1.b requires the same reportability for inoperable radioactive liquid ef fluent monitoring ' , ,, g bt g - e< M f

L , ., . g " h b , , , .j i . ,

.. a ' .m __ kh5 y

' A yy? [ ' , &W, ; q [[" A , . innt'rumentation; for. the same four and a half year. period, the- ' ?? ? .I f9 . licensee did:not' report any! failures to return liquid effluent ' %pi 3.' instruments to operabil.ity within 30 days.. This appears. to represent ' ' good' licensee performance regarding maintenance and repair of T/S.

' y" ' @M effluent monitoring instruments;: however,.because the. licensee failed ', to reportiun abnormal release in a. Semiannual Radioactive Effluent ,f . Release'P.eport (see Section 11) apparently due to an inadequate procedure,Lthe potential exists for failures to report' instrument . operability-problems.

This. matter was discussed with a licensee &L-representative'on October 4, 1988.- In response to the inspector's uI

{4 d concern, the licensee initiated appropriate corrective action by 1 drafting a revision tc Procedure No.'HP 10.5,' Palisades Semiannual P Radioactive Effluent. Release'lieport, to require that the. licensing-j ' event and-deviation report logs be checked for any effluent j ' k,

'instrumentation operability problems.

8ecause the 1icensee C initiated appropriate corrective action before the end of the y inspection, this matter is closed (0 pen Itein Ho. 255/89025-08).

j, , & . Pursuank ta T/S. 3.24.2.1.b,' the licensee reporteo a f ailun :o ( ' ?~ return gaseous effluent in3trumentation to operable status within

30 days in the Semiannual Radioactive Effluent Release Report for j

the first half 'of 1987.. T/S 3.24.2.1.b and Table 3.24-1, actions .; c , 3n and'31M further stipulates that "adioactive gascuus o fluent

r , ' ' releases may continue with less.than the' required number of operable ' gaseous effluent monitor channels providing that'the flow: rate it '; r , , i 9stimated at!1 east once per 24 hours for cantinuous releases or once ( -

per every four hours for batch releases.

On June 4, 1987, WGDT T-68C t N . (batch No. 87-018-G) was scheduled for release; however, due to poor

f communications during. shift turn-over and the lower than usual

', release rate, the flow rate estimate was not performed.

The ' ' - @' radioactive paseous effluent monitor had originally been declared i V' in' operable on March 5, 1987.

Due to an extended time.neriod to j ' troubleshoot the problem and obtain parts (12 weeks) plus.an

V . additional loud timo (8 weeks) for repair, work completion was- ' j estimated'for August 7, 1987.

Pursuant to 10 CFR 50.73(a)(2)(i), ' . im the licensee issued LER No. 255/87-017'00.

d .. y ,b.

TAchnical Specificatio_n_,,Sp,ecial Reports, of Inoperability L y , w.

t k* o Technical Specification 3.24.2.1.b and Tabin 3.24-2, Action 38 j F requires the licensee, that with less than the minimum channels , % operable, to initiate the preplanned alternate method of monitoring i J .the. appropriate parameter (s) within 72 Nurs and either restore ),$ the inoperable channel (s) to operable status within seven days or < , y preptre and submit a special report to the Commission pursuant to f %l T/S 6.9.3.3.6 within 30 days following the event outlining the ' <

action taken, the cause of the inoperability and the plans and i b}g }, l' schedule for restoring the system to operable status.

Action 38 l is. applicable to the high range noble gas stack effluent monitor i $ (RIA 2327), the main steam safety and dump valve discharge line , eS ; gross gawa activity monitors (RIA 2323 ar.J 2324), and the i 4'.

engineered r,afeguards room vent rystem nuble gas activity monitors j

', ! .p , ', ,

'-,

a _' ( CS @w, 1g A > ,, , . _ ,

. 3k D,Y +H ' ' ' ,' .; ny, a , - - . e y ;.g u ,

hy WW l

' ' < , mm, @%N, ' ' E(RIA 1810land 1811).' T/S 6.9.3.3.b requires that special reports be $ %, submitted in accordance with 10.CFR 50.4,.within the. time period ! t

specified for each report.

The' licensee reportedly submits special; ! ' M @; reports as' voluntary LERs with the desigaation, TS;.aven though they j "(' U 3 are not reportable pursuant to 10 CFR 50.73. The3 inspector reviewed i i - tis TS LERs for 1988 and' to,date in 1989' to determine:if Action ~ 38 i &L ihad.been invoked; the'one identified. event is. discussed below.

9! * (Also, LER No. 255/87 033-00, Detector Failure and Inoperability i y1 ' Greater :u Seven Days Results in Technical Specification Special , MQ Report, m ER No.' 255/87-034-00, ' Inadequate Procedure Results in , 5 a: .Rodioactive Effluent Tc.:hnical Specification Noncompliance, are ~t

discussed in Section 21 of Inspection: Report No. 50-255/87030(DRSS).)- p... . -Voluntary LER No. 25f/89-TS1-00 was issued on June 22,,1989,. < % pursuant-to T/S 3.24.2 Action Statement 38 yhn.n requires that ~ , > ..g ; ' lthe minimum number of operaLie channels be restored within seven days j A: ? or a special report be submitted within the following 30' days.

At . ,4 1035.on.May 16,,1989, the West Enginecting Safeguards Room (WESR) C radwnte ventilation isolation monitor (RIA 1811) slowly. failed

downscale and was-declared inoperable.

In accordance with T/S- ! ' - , Table 3.24-2,salternate methods of' assessing the WESR environment I . % 'were. implemented per Procedure.No.'HP 6 J1, Rattiological-Effluent -

'

_ e v.

Operating Procedure.

However, the radiation monitor was not returned' , i to service within sovon days; RIA 1811 was repaired, tested, and-

declared' operable at.2200~on May 24, 1989. The monitor. failed when ! ' g water originating from maintenance on the waste gas vent collection l >- header l contacted the monitor and failed its pre-amplifier: board.

-

W The waste pas vnt collection header was cut into to remove blockage,

, believed to be. spent ion en hange resin which was expectedito be dry.

! - ., p The u". expected water is believed toL have originated.from 1986 resin , ' sluicing activities.

While sluicing.' resins from the spent resin g > storage tank T-69, an overpressure was applied to provide the motive ' force for moving resins out the top of the tank.

Until approximately ij ,m @' 1986, as difficulties were experienced with resin outflow, Operations t personnel would reportedly.open the tank's. vent to relieve precsure j - , @R (which allowed water and resin-to enter'the waste gas collection

header).

The failure to return the.:,onitor within seven days as , E ' required by T/S has been attributed by the l'icensee to failure to j apply appropriate attention to secondary action statements cuch as Action Statement 38.

To enhance management attention of secondary > %D . Action Statements, Ocerations personnel will add these actions ! ' 4g stat,ements to the Plant Daily Status Sheet and will identify them iC on work orders, so that appropriate priority is given to scheduling

'

repairs.

8' c.

Radiati.. i Monitor Q-List s . In Inspection Report No. 50-255/89015(DRP), Subsection 2.e, Open b Items No. 255/86035-96(DRP) and No. 255/86035-109(DRP), Perfor ~; $ ; Q-List interpretations for Safeguards Room Ventilation Radiation ~ Monitor sample pumps (P-1810 and P-1811) and the Radwaste Ventilation

P Monitor (RE-1809), were closed.

As a result of licensee evaluations, [X P-1810 and P-1811 are now Q-listed.

The Material Condition Task ' ., . j{ Q ' } W .

g%m.

' . g.

i , ' & %lR.

' mi A : W.

- .. . ,, -

t

W ;; ~'p ? C' @k .,, ^ If.

,

. , , s ' ymf , , , > y .7 k ' r

, L: M ' p' Force' recommended:a Q-list interpretation be. performed for RE-1809 , . based on prior ~ ro'li_ ability problems.

The interpretatior, was ' ,, h initially performed in 1987 and revised in February 1989.

The ' iL NRC determined that the licensee's actions app 2ared acceptable R in both cases above..In Subsection 2.f of the same inspection ' k reportJ 0 pen Item No. 255/86035-102(DRP), Perform Q-list' ' , F interpretation and replace monitoring system for IIA-2318 Stack ' ' ' Gas Monitor Radiation Alarm, wa. closed.

RIA-2318 is a Q-listed ' backup-nobic gas. monitor for RIA-2326 and.is subject to T/S 3.24.2, Table'3.24-2 requirements.

After extensive maintenance, the - , electronic portion of the.monite= vas considered reasonably reliable;

however, the' mechanical portion (sample'tt osport) was not.- The r I' . licensee stated that this monitor is normally' shutdown with RIA-2326 ~normally operating and that a T/S charge request a s in preparation ! < E to delete RIA-2318 from the T/S.

Further, the licensee has a long P term radiation monitoring upgrade program in progress with funds budgeted in the-Five Year Plan for progressive replace ent of the existing system through 1991.

d.

Instrument Upgrade Program , f The inspector reviewed the Radiation Monitoring System (RMS) z < portion of the Instrument Upgrade Program Five Year Plan and

Appendix C, Plant ~ Equipment > Status Cbservations and Resolutions, of the licensee's Material Condition Task Force response to the NRC's May ??,1986 Confirmatory Action Letter.

The inspector also discusscd the RMS' improvement program with appropriate licensee , representatives ~, including the.RMS system engineer.

The instrument upgrade program acknowledged that' much of the plant instrumentation , has exceeded design life, resulting in frequent repairs or difficulty in obtaining spare parts.

The program objectives are to identify - . ,4 the obsolete or high maintenance components'ar.d replace them with ,. l' state-of-the-art equipment; in the short term, this includes the

upgrade of 47 radiation monitors.

Part of the five year plan

e ! includes consideration of' replacement of all area monitors, upgrade of the Victoreen RMS, and upgrtde (or replacement) of effluent and process RMS.

Ducumentation reviews and nersonnel interviews i/ indicate thrt the RMS upgrade program is thorough and comprehensive; . the implementation seems to be timely and appropriate.

pf Radiatbn Monitor Reliability Trending e.

The inspector reviewed the Sacond Quarter 1989 RMS trend report and

discussed the contents with the RMS system ergineer.

There were 20 [ n.

,, '. ' " active work orders (W0s) on 17 area monitors (RIA) for a total of' ' 645.5 manhours and 20,383.5 out-of-service (005) hours; 15, 4, and 1 W0s were for repair, setpoint adjustment, and vitor failure, respectively.

There were 8,088 additional 005 hours from the WO

becklog, yielding a percent availability for the 37 RIAs of 64.8%; ' < due to the equipment upgrade project, two additional RIAs have been

-

00S since July 27 and August 8, 1988, and will not be repaired by - the vendor until the 1989 maintenance outage.

There were four W0s l8 k) 'f'g ?.i; Ls y

gs s , mem x y v, y -- ' "' ., - ' , . . . .

t.

~

" , ,

, ., ,pY . sl' , ' , n .. J, E- 'for three process' monitors for a total of 300 manhours and 719 005- ' 'W hours; 2, 1,.and 1 W0s were for monitor failure, no. signal, and , o" failed low, respectively.

The percent availability of the 23

process monitors was 98.6L The data presented in the trend report , rand discussions with the RMS system engineer clarify the primary ,

' objective of the five year RMS improvement plan, which is to , consider replacement of all area moniters and either the replacement or upgrade of the process monitors.. Although the licensee has a , - ' . , feirly good corrective maintenance for the process monitors, the - ; yJ area monitors imve been too unreliable for a corrective maintenance .. program to be effective.

' ,, y f.

Radiation Monitor Surveillance Program

The inspector reviewed the Technical Specificat'.ons Surveillance @ Procedure Basis Document'for Process Monitor Functional Ciecks, Procedure No. QR-22; Palisades Nuclear Plants iechnical Specifications

' Surveillance Procedure, Process Monitor Functi>nal Checks - Quarterly, , Procedure No. QR-22; and selected documentation of completed ' acceptability criteria and operability surveillance tests, no significant problems were noted.

It was'noted, however, that even ' e thcugh all acceptence criteria may be met, work orders are written when monitors, their indicator systems, recorders, alarm system, ' i etc., are functioning less well.than desirable.

This conservative approach to improving monitor performance is. a good pra:tice, which " sho'uld have a significant positive impact on monitor reliability.

' g.

RMS Responsibility and Coordinati_on

L' The responsibility for the PMS is shared by RSD,.0perations, I&C, System Engineering, and Maintenance.

These departments usually work well together with some occasional coordination problems which sometimes lead to T/S "iniations or extended 00S periods; however, , corrective actions to prevent recurrence are usually adequate and better oversight of the RMS upgrade program should eventually reduce < l-00S times.

Until the RMS is sufficiently upgraded, it.is desirable to somewhat improve coordination between departments and increase ' - RMS WO priorities to improve RMS availability.

g ' No violations or deviations were identified by the inspector; however, . one open itc'n was identified.

13.

Access Control for Areas with Radiation Levels >1 R/hr (IP 93702) T ) Previously identified weaknesses of the licensee's access contN1 for areas with radiation levels >l R/hr are discussed in Inspection Reperts No. 50-255/87005(DRP)', No. 50-255/87030(DRSS), No. 50-255/88006(DRSS), and No. 50-255/88023(DRL).

In the latest of there inspection reports, 'i . dated January 3,1909, the NRC issuea a Notice of Violation (NOV) because ' , the failures on June 10, September 30, and December 17, 1987, and on September b and 7,1988, to maintain locked doors to prevent unauthorized < 1f access to areas >l R/hr were violations of Technical Specification 6.12.2 , , f I

. f ',l b

, . ., . . . .. . a

\\W + , ,1 M n% A4 , .V-j ? m L s , p< (Violation No. 255/88021-06), and'although these violations were ^

predominantly licensee-identified, licensee corrective measures to y date had not been adequate to prevent recurrence.

, . , E On February 2, 1989, the licensee transmitted to the NRC a written response to the above violation which included corrective actions taken

" and results achieved,-corrective actions to be taken to avoid further

non-compliance, and the,date when full compliance will be achieved.

The .; licensee stated that the root cause of all five events has been attributad ! to inadequate' personnel performance, the responsible individuals have

been counseled as to the significance of the failure, and all RSTs have i been trainedLas te the importance of maintaining control of IR door keys '

and the 1R door key log.

The licensee also delineated the tighter - 'j. controls that had been impicmented for storage and use of 1R door keys.

' ' Corrective actions to be taken to avoid further non-compliance included a , program to provide secondary independant verification that IR doors accessed have been locked and a Management Review Board with the Plant - General Manager in' attendance to be held with any individual' identified o to have-failed to properly secure a 1R door.

The licensee stated that the board will provide a review of the incident and senior plant y management involvement in determining appropriate corrective action.

, + Among~ the licensee commitment dates for achievement'of tull compliance were that inventory of 1R dom keys would be completed by April 30, 1989, , and the secondary verification program would be implemented by February 28, 1989.

,, m Despite the above corrective actions to preclude recurrence, on June 30, . 1989,-the 1R door to the Dirty Waste Drain Tank-(T-60) Room was P' . discovered by a RST to be unlocked and unattended; thus not providing l positive control over entry to the area.

Inspection Report

L No. 50-255/89018(DRP) documented that this incident appears to be a ' violation of regulctory requirements and will be followed up in a ' subsequent NRC. inspection (Unresolved Item No. 255/89018-03). The licensee issued Deviation Report No. D-PAL-89-126 to document the ! incident investigation, root cause analysis, and corrective actions. ! ,. The licensee determined that an auxiliary operator (AO) haJ signed l. out a 1R key to enter the Spent fuel Pool Heat Exchanger (SFP Hx) L Room, later used the same key to enter the T-60 area to perform other o assigned tasks without indicating on the 1R key log that he was also L going to enter that area, forgot to lock the T-60 Room door, but correctly had another individual verify that the SFP Hx Room door was locked,.and the' verification signature for the SFP Hx Room door being properly locked was placed in the IR key log. Similar to the , I' five earlier incidents that were the subject of the aforementioned NOV, the licensee determined that the root cause of this incident was

due to a human performance deficiency. The licensee's investigation indicated that no work was scheduled in the T-60 area and apparently ' i no individual entered the atea in the interval between the time when the A0 left the area with the door unlocked and the time the RST found j. the door unlocked and subsequently locked the door. '

f g

'

w e < cy '

,f< , < '

. ' - - ! , , , k' Or July;10,'1989, a Management Review Board determined that additional

administrative controls should be, implemented and that Health Physics ' should r.ot issue-1R door keys until proposed actions to prevent i y recurrance have been addressed. At the time of the conclusion Of the

1 'onsite inspection, Health Physics personnel were still denying A0s ! > access-to 1R keys because proposed administrative controls had not yet

been implemented. These proposed controls include (1) installation of distinct and' separate keys for.the four 1R area doors where A0s cccomplish routine tasks (T-60 Room, SFP Hx Room, SWRT Room, and the 602-ft south ' 'pipeway),-was. completed on October 7, 1989 (locks for these four doors are ! , . reportedly of:the type that'the key cannot-be removed from the lock <. core / padlock core unless the core is in the locP.ed position and since

the old locks remain installed, the doors are double locked); (?) evaluate

the installation of alanas on the doors to alert the person leaving the ' area that the latch / lock is not secure, which was completed on September 20, ' 1989 with the interim recommendation not to install the alarms; and (3) a re-evaluation'of the controls for 1R doors in containment during outages, ' which was completed.on September 19, 1989, by issuance of Revision 1 to

RSD Policy and Practices MemorLndum No. 89-002, 1R Door Verification, that specifies much tighter controls over 1R doors in containment during power operations and outages.

', .Although the above proposed corrective actions have achieved the status of interim resolution, there is some opposition with RSD and between i departments regarding the final disposition of this matter. Also,QA must conduct a completion review to assure all requirements are met and that closure of the deviation report is appropriate. Meanwhile, The , denial of 1R keys for A0s makes the RST staff somewhat less efficient in that~in addition to all other requi,*ed duties, the RSTs must accompany , , l .A0s to work. assignments in 1R locked areas, unlock the IR doors for the l' A0s,'estab71sh positive entry control until the A0s complete assigned ' L tasks, lock the IR doors after task-completion, and vs.rify that the 1R doors are. locked and key log properly coitpleted. The second verification requireuents may be waived by the HP Superi tendent for containment outage work activities if stringent criteria established by Memora.1dur. 89-002 (Revision 2) are met. ' A review of Procedure No. }lP 2.5, Entry Control for High Radiation Areas Over 1R/hr, Revision 8, July 21, 1989, indicates that the present wording , could be clarified and more explicit in that the procedure does not appear to specifically require A0s to declare each area of entry and the associated verification that each 1R door was locked after task ' completion (61though these requirements are implicit in the text and key log form, and in RSD Policy and Practices Memorandum No. 89-002 , (Revision 2)). Prerequisite No. 3.3 of Procedure No. 2.5 states that ( operations personnel with advanced radiatior worker training and qualifications for self monitoring may make one person entrios into all high radiation areas except those areas requiring two people. As stated

> ' in Section 8 of Inspection Repcrt No. 50-255/88021(0RSS), the inspectors discussed with RSD supervisory and managerial personnel the importance of maintaining adequate RSD oversight of the advanced radiation worker i

24 ' .s , y f' _, . ,., .,. , - . - _.-_, - - -. --

n > , ,s , j,o '{ 'T: b uGL g j p . , > . <., . ,

, [f ? . training and quali'1 cations programs for A0s and the desirability of

taking appropriate action if the privilege of self-monitoring-is abused, , p The inspector concerns regarding procedural, training, and qualification

' L adequacies were discussed with appropriate licensee personnel, o ' Despite the licensee's attempts to institute effective corrective action ' .to prevent recurrence of the 1987 and 1988 failures to maintain locked doors to prevent unauthorized access to areas >1R/hr, on June 30, 1989,

, E .the licensee found the IR door to the Dirty Waste Drain Tank (T-60) Room + unlocked and thus in violation of Technical Specification 6.12.2.~ - .

The licensee's extensive completed / planned corrective actions in response i " c ^to-this latest violation appear adequate'to prevent further recurrence. Although the NRC endeavnrs to encourage licensee identification and

correction of problems through discretionary use of the enforcement

e policy (10 CFR Part 2, Appendix C), the licensee's'past failure to ' implement effective corrective actions to prevent recurrences of this violation necessitates the issuance of a Notice of Violation for this

1atest incident _(Violation No. 255/89025-09). One viciation was identified. . 14. Air Cleaning Systems (IP 84750, 847?4) i Technical Specificutions (T/S) require filter testing of the Control Room Ventilation and Isolation System (CRVIS, VF-26) and the Fuel Storage Area

HEPA/ Charcoal Exhaust System (FSAES, VF-66) as specified by Surveillance Requirement Table 4.2.3, HEPA Filter and Charcoal Adsorber Systems. The inplace leakage test criterion specified for both'the 00P testing of HEPA filters and freon testing of. charcoal adsorbere is equal to or less than L one percent penetration. The laboratory test criterion for carbon sample y R removal efficiency for methyl iodiue is equal to or greater than>94

. percent. Procedure No. RT-85C,D, Technical Specifications Surveillance Procedure Basis-Document for Inplace HEPA and Charcoal Filter Testing, Revision 1, August 7, 1989, establishes more stringent filter testing requirements for VF-26 in that the CRVIS inplace leakage test criterion - specified for both the 009 testing of HEPA filters and freon testing of ' % charcoal adsorbers is equal to or less than 0.05 percent penetration, and ,' f the laboratory test criterion for carbon su,le removal efficiency for methyl iodide is equal to or greater tnan % percent; the test criteria for the FSAES (VF-66) are the same as the T/S Surveillance Requirements. l

On May 11, 1989, the licensee issued LER No. 255/89-008-00 to report , to the NRC, pursuant to 10 CFR 50.73(a)(2)(i), a failure to meet T/S . Surveillance Requirements identified in Table 4.2.3 pertaining to .", 9 meillance testiag of spent fuel pool ventilation system (VF-66) , , charcoal adsorbers; the LER was closed in NRC Inspection Report L No. 50-255/09018(DRP), transmitted to the licensee on August 11, 1989.

1. The LER states that on April 12, 1989, Corporate Quality Assurance (QA) personnel identified that representative samples of the charcoal adsorber sent to a vendor for iodine removal efficiency testing did not meet the yf required 94 percent acceptance criterion on October 7,1988, results of ' ' ' the testing were not received within the required 31 days (45 days had elapsed between sample removal and sample testing / receipt of results), and the resultant system inoperabi'.ity was not recognized by the licensee

, , -}.' '. 'f _ , . . _, _ _ _ _ _ _, _ _ _ _ _ _., _ _ _ _. _, _ _., _ _, _ _ _ _ _ _, _ _ _ _. _

- - ,,

(,

[4

,g i 4 v a ';, a, ,

,, ? @. until the QA' audit. The inspector reviewed the licensee's performance ' regarding this matter (discussed below), although the resident inspectors ... had previously reviewed the licensec's corrective actions as documented ' in event report No. ' E-PAL-89-018, found them acceptable, and in 'accordance with 10 CF2, Part 2, Appendix C,' Section V.G.1 determined ' ' that a-Notice of Violation will not be issued (Violation No. 255/89018-04). ! ! . i, ' NRC Information Notice No. 87-32, Deficiencies in the Testing of

' E' Nuclear-Grade' Activated Charcoal, was closed in Inspection Report ' No. 50-255/87030(DRSS) because the licensee's charcoal testing vendor

4

reportedly uses.the testing protocol which the information. notice t ' a ~ designates.as acceptable. According'to vendor representatives, on n' October 15, 1987, a sample cell of.onsite charcoal was tested with methyl

p~ ~ iodide at 30 C and 95% RH, using the testing protocol recommended by l .IN 87-32. When the sample results indicated essentially 100% penetration, the vendor reportedly discussed with the licensee the unacceptability of the charcoal and concern regarding the adequacy of the storage facility. On May~5, 1988, a VF-66 charcoal sample showed a methyl iodide efficiency - of 53.576% when tested with the IN 87-32 recommended protocol at 25'C and ! 95% RH; Work Order (WO) No. 24802986 wa: initiated to replace the VF-66

,

. charcoal adsorbers. On June 10, 1988,.the charcoal'adsorbers (27) and h. sample canisters'(4) were replaced per the WO; 24 adsorbers and the four'

[ . sample: canisters were procured under Purchase Order (P0)'CP11-3701Q and .; ' the remaining (3):adsorbers under P0 CP11-1058. Although the QA auditors

identified that it was improper to use sample canisters from P0 CP11-3701Q t ' p (received in February 1986) to represent the adsorbers installed from < P0 CP11-1058 (received in September.1983) and that there was no requirement ! lJ to vendor-test the replacement charcoal, apparently they did not express 'l concern regarding the earlier vendor-identified stored-charcoal viability

, problems. On October 7, 1988, the vendor notified the licensee that the , h VF-66 sample demonstrated a methyl iodide removal efficiency of 89.855% using the IN 87-32 recommended protocol at 25'C and 95% RH. The charcoal o ' adsorbers were replaced and declared operable on March ?0,1989, iiith the successful completion of RT-85C; the VF-66 system had apparently been - inoperable since at least May 5, 1988. Further corrective actions are

, discussed below.

l~ The failure to maintain charcoal adsorber efficiencies within the T/S L limits has been attributed by the licensee to improper storage of spare

charcoal for the ventilation system and improper scheduling of the required efficiency testing. The licensee concluded that the charcoal t may have degraded due to storage in an environment which is not , temperature and humidity controlled or while installed due to the l- potential presence of unknown or unmonitored airborne fumes to which I y charco11 adsorption properties are susceptible. As corrective action to preclude recurrence, an agreement has been signed with the testing vendor i to provide for appropriate storage of cnarcoal trays and maintenance of . tray ~ condition (as well as to refill. rays with acceptable chariOal and

return when required), and appropriate system operating procedures and Operations Departmer,t checklists have been or will be revised to provide

for' logging VF-66 operating hours to assure to the extent possible that , ,' adsorber contaminating fumes are not drawn into VF-66 during operation. Because personnel involved in Plant Corrective Action Review Board (PCARB) on October 7,198, failed to recognize that adsorber test results

, , b . , , _

( Cy & ' , .

W , x , m , n i" indicated that VF-66 was-insperable, and that this condition was required , to be reported to the NRC, these persons, as well'as. plant personnel , '. involved in reportability determinations and all PCARB Chairmen, have reportedly, beer, made cognizant of this event to prevent recurrence. Also, T/S Surveillance Test Procedure No. RT-850,0 has been revised to . address' test scheduling, plant conditions allowed for test performance,

clarification of T/S requirements, and a requirement for plant material ' E management to sign-off receipt of sample test results within T/S required' l . time. limits. The NRC's assessment of the licensee's performance in this

' matter. and the overall quality of the licensee's filter testing program- ! L are discussed below. Although the QA a'uditors conducted a ti.orough and commendable review of the above event and the corrective actions were appropriate and timely, it

. appears that the licensee knew of the likelihood that the onsite stored charcoal'would. fail'the methyl iodide efficiency test'for approximately st .one year before the failure on October 7, 1988, and st.ould have been '

cognizant of the-T/S. requirements to nave prevented an ESF system (VF-66) being inoperable for at least 11 months without discovery despite - numerous' opportunities.for early, detection. Because of the licensee poor ^ performance.regarding this event represented an apparent pre-existing .g significant programmatic problem (which presumably has been corrected), the-inspector selectively received recent filter surveillance tests to .' ascertain if there were further programmatic problems. Although the surveillance tests reviewed indicated VF-66 and VF-26'had met test acceptance criteria, two additional programmatic concerns were noted in that (1) the' methyl iodide testing conditions specified to the vendor ' 'showed inconsistencies and (2) in some cases the testing protocol

H recommended by IN'87-?2 had not been used (contrary to information ' previously supplied to the NRC by the licensee and documented in ' Inspection Report No. 50-255/87030).

m

i Specifically, the protocol of the VF-66 October 7,1988 test i'icluded equilibrium, loading, and post-sweep times of 16, 2, and 2 hours, respectively at'25 C and 95% RH (although the P0 inconsistently specified testing per ANSI N509"776 and R.G. 1.52-78); the protocol of the VF-26 (Train B) April 30, 1989, test included equilibrium, loading, and , , post-sweep tirtes.of 0, 1, and 2 hours,'respectively at 25"C and 95% RH + (the P0 specified testing per ASTM D3803-79, Section 3.1, Method A for used carbon); and the protocol for the VF-26 (Train A) October 13, 1988, , and VF-26 (Train B) November 4,1988, tests included equilibrium, loading, and post-sweep times of 0, 1, and 2 hours, respectively at 25 C ' and 70% RH (the P0 specified testing per ANSI N509-80 and ASTM D3803, Method A). Included among the problems associated with just these three examples are the fact that none of the test protocols (including

temperatures and relative humidities) is that recoinmended by IN 87-32,

p all three protocols are different and the specifications on the r0s are ef different and do not match the testing protocols used. The licensee ' appears to have a serious programmatic problem regarding methyl iodide charcoal adsorber testing. The inspector also noted during the review of the inplace test reports of HEPA filters with DOP and charcoal adsorbers with freon that in some cases there was a significant , scattering of test data points which may be indicative of poor test S quality and perhaps an invalid test. It seems appropriate for the ,. hr

! y , kLC . . _, '

p+ , -

1 , . y , , . ' ' ys u.a r :- p -; ' q , , . ,

licensee to' review the adequacy of'these tests, the testing equipment

i

and methodology, and'possibly the training and. qualification ~of the

. testing personnel. '

u , L - , The above programmatic concerns were. discussed at the exit meeting will , , be reviewed further during a future inspection,'and pending-completion of H ' . L thilicensee's evaluation of their filter: testing program adequacy, this A matter.is considered an' unresolved item (Unresolved Item No.. 255/89025-10). R On October 9, 1989, the' inspector was informed that the aforementioned charcoal sample, which showed essentially 100% penetration.on October 15, ' .' 1987, was from a containment air cleaning unit, no charcoal has been tested from these units since that date, and'the units have apparently

not been effective in reducing airborne concentrations in containment. ]

i It appears desirable for.the licensee to evaluate the adequacy of.the j ope' rational requirements for containment air cleanup units. This matter J was discussed.at the exit meeting (see Subsection 16.k) and will be l t reviewed further during a futur'e inspection (0 pen Item No. 255/89025-11). -

No violations:or deviations were identified; however, an unresolved item and.an open item were identified. l 15. Primary Coo 16nt Radiochemistry (IP-84750) Technical Specification 3.1.4 requires that the specific activity of the primcry. coolant not exceed one microcurie'of I-131~ dose equivalent per ! gramexceptundercertainlimitingconditionsofoperation. The inspector ' selectively reviewed the licensee s primary coolant radiochemistry , .results for the past year (June 1,1988 through August 15,1989),to , determine compliance with the Technical Specification requirements for .the I-131 dose equivalent (DEI-131) concentration. The selective review , and discussian with licensee personnel indicated that the DEI-131 l concentration for the primary system remained less than the applicable

' Technical Specification limit throughout the review period.

No' vin 1ations or, deviations were identified. L 16. Exi t' Meetina -The inspector met with licensee representatives (denoted in Section 1) at'the conclusion of the onsite inspection on August 18, 1989, and by - telephone on October 9, 1989. The inspector summarized the scope and ' findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The ~ licensee did not identify any such documents or processes as proprietary. t The following matters were discussed spe::ifically by the inspector. , , a. Management support of RP/radwaste programs has been extensive with ? resultant improveme 's in several areas, also some areas appear to require 6dditional minagement attention. (Section 4) ' , , b. Decontamination of the south radwaste building and disposition of the adjacent contaminated soil. (Section 3)

6

,, ! < ,g ' O f ri , .,.. > , . .. .

m py / 9x , v- > > ,, ' yR =;a , , c., Failure to follow procedural l requirements'regarding conduction of.an engineering evaluation before shielding placement. (Section 3) ' - d. ApparentneedtoperformanLevaluationtoidet'ermineifcontainment depressurization/ vents should.be batch releases. On October.10, ' 1989, the licensee issued Action Item Record (AIR) No. A-PAL-89-124 to perform this evaluation; the ARI requested completion date is May 29, 1990. (Section 6) ' , e. Apparent need to conduct an acceptability evaluation of the S/G and hotwell release program. (Section 7) I f. Failure of.a radwaste shipment to meet burial site requirements. I (Section 9) a g. . Failure to report an abnormal gaseous radioactive release in the ' Semiannual Radioactive Effluent Release' Report. (Section 11) h. Procedural requirements should be revised to ensure that effluent " ' instrumentation inoperability is properly-reported in the' Semiannual > Radioactive Effluent Release Reports.. (Section 12) 1. Failure to lock a 1R door as required by T/S 6.12.2.- (Section 13) j. Apparent need to evaluate the adequacy of the air cleaning system o ' filter testing program. (Section 14) a p L. Apparent need to evaluate the adequacy of the operational requirements for the containment air cleaning system. On October.30, v.e " 1989, theilicenses issued AIR No. A-PAL-89-122 to review the adequacy of the current containment iodine removal system testing and charcoal' replacement practices, and AIR No. A-PAL-89-123 to review the adequacy of the current operational practices for this system. The requested j completion date for both AIRS is Mav 29, 1990. (Section 14) i ! -

..

n , c' i I ' a ' s Y I

h; +

'

x

}}

v t e Inspection Report - Palisades - 1989025
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1989 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 9(0) 10(0) 11(0) 12(0) 13(0) 14(0) 16(0) 17(0) 18(0) 19(0) 21(0) 22(0) 23(0) 24(0) 25(0) 26(0) 27(0) 28(0) 29(0) 30(0) 31(0) 32(0) 33(0) 34(0) Security Operator Exams Emergency Planning Other

IR 05000255/1989025

Text

REGION III

Inspection Report

Navigation menu

Search