IR 05000255/1989030
| ML18054B175 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/05/1989 |
| From: | Gill C, Miller D, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054B174 | List: |
| References | |
| 50-255-89-30, NUDOCS 8912140290 | |
| Download: ML18054B175 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/89030(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
October 31 through November 21, 1989 Inspectors:
Approved By D. E. Miller i.J rs 9o~T ~
W. G. Snell, Chief Radiological Controls and Emergency Preparedness Section Inspection Summary License No. DPR-20 Date'
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11-(</'1 Date Inspection on October 31 through November 21, 1989 Report No. -50-255/89030(DRSS)
.Areas Inspected:
Routine, unannounced inspection of the radiation protection program during a maintenance outage including:
organization and management controls (IP 83750), changes (IP 83750), planning and preparation (IP 83750),
training and qualifications (IP 83750), external exposure control (IP 83750),
internal exposure control (IP 83750; 83725), control of radioactive materials and contamination (IP 83750; 83726), maintaining occupational exposures ALARA (IP 83729; 83728), audits and appraisals (IP 83750), and open item Results:
The organizational structure, management controls, staffing levels, and upper management support for the radiation protection program during the outage appeared generally adequat During plant tours, no significant access control, posting, or procedure adherence problems were identified; housekeeping was generally good for the outage condition Program strengths noted during the inspection included t~e reconfiguration of the access control facility to enhance contamination control (Section 10) and initiation of a comprehensive radiation source reduction program (Section 11).
Matters that need continuing license attention include efforts to reduce the number of personnel contamination events (Section 10) and to reduce personnel radiation exposure (Section 11).
No violations or deviations were identifie PDR ADOCK 05000255 Q
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DETAILS
- Persons Contacted D. Anderson, Senjor Quality Assurance (QA) Consultant
- C. Axtell, Senior Staff Health Physicist
- W. Beckman, Radiological Services Manager
- E. Bogue, ALARA Coordinator
- J. Brunet, Licensing Analyst N. Campbell, Senior Health Physicist M. Dickson, Radiological Safety Supervisor G. Ellis, Radiological Safety Supervisor
- J. Hodl, QA Consultant
- L. Kenaga, Health Physics Superintendent C. Kozop, Technical Engineer D. Malone, Senior Licensing Analyst
- M. Mennucci, Radiological Safety Supervisor T. Neal, Radioactive Materials Control (RMC) Supervisor
- G. Slade, Plant General Manager
- W. Axelson, NRC, Chief, Reactor Projects Branch 2
- B. Burgess, NRC, Chief, Reactor Projects Section 2A J. Heller, NRC, Resident Inspector
- E. Swanson, NRC, Senior Resident Inspector The inspectors also contacted other lic~nsee employee *Denotes those present at the onsite exit meeting on November 9, 1989.
- Denotes those contacted by telephone during the period November 13-21, 198.
General This inspection was conducted to review the radiation protection program during an extended maintenance outag The inspection included tours of the onsite facilities, observation of work in progress, review of records, and discussions with licensee perso~ne.
Licensee Action on Previous Inspection Findings (Closed) Open Item (255/8802101):
Licensee needs to reevaluate the apparent desirabiljty of improving MPC-hour determination methodolog This matter was discussed in Inspection Reports No. 50-255/88021 and No. 50-255/8902 During this inspection, the licensee questioned the intent of the open ite After further discussion between the inspectors
- and the licensee, the licensee stated that they would:
(1) determine the adequacy of their radiological procedures for making MPC-hour estimates for intakes of radioisotopes expected at an operating PWR and (2) make necessary changes to th'e appropriate procedure Si nee the scope of these ite~s has changed, a new open item will be used to track resolution of this matt~r (Open Item 255/89030-01).
- Organizations and Management Controls (IP 83750)
The inspectors reviewed the licensee's organization and management controls for the Radiation Protection Progra~ including the organizational structure and staffing, staff stability, effectiveness of procedures and other management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse A reorganization of the Radiological Safety Department (RSD) occurred on October 1, 198 The HP Superintendent (HP Operations Group), the Senior Staff HP (HP Support Service Group), and the Radioactive Material Control (AMC) Administrator (Rodwaste Group) report directly to the RSD Manage The ALARA Coordinator (assisted by four Radiation Safety Technicians (RSTs) and one Nuclear Analyst), the instrumentation/respiratory protection Radiation Safety Supervisor (assisted by seven RSTs), the surveys/duty-HP Radiation Safety Supervisor (assisted by five RSTs), the technical support Senior HP (assisted by one RST), and the Dosimetry Senior HP (assisted by two RSTs and a HP Specialist) report directly to the HP Superintendent.. The Senior Staff HP is assisted by a Senior HP, a General HP, a Radiological Engineer, a Senior Nuclear Operations Analyst (training coordinator), the Senior Emergency Planning Coordinator, the Emergency Planning Coordinator, and two RST The RMC Administrator is assisted by the RMC Shipping Supervisor, the Decontamination Supervisor, the Industrial Hygiene Support Coordinator, the RMC Support Coordinator, an Engineering Technician, four RSTs, and twelve Radwaste worker The low turnover rate of RSTs and the management support of the RP/Radwaste Program is discussed in Section 4 of Inspection Report No. 50-255/89025(DRSS).
No violations or deviations were identifje.
Changes (IP 83750)
The inspectors reviewed changes in organization, personnel, facilities, equipment, programs, and procedures that could affect the outage radiation protec~ion progra During this outage, the station and contractor RST crewleaders are providing continuous coverage, seven days per week, by working twelve-hour days, five days per wee Duty-HP continuous coverage is provided by rotating four individuals in that position every four days for the t~elve-hour day and night shif Evidence of contract RST oversight is exhibited by the licensee's policy of appointing station RSTs as crewleaders and assistant crewleaders, with the exception of a few contract assistant crewleader This scheme, combined with tours by the Radiological Safety Supervisor, Health Physicists, the ALARA Coordinator, and the HP Superintendent, appear to provide adequate oversight of contract RST activitie No violations or deviations were identifie '**
- *Planning and Preparation (IP 83750)
The inspectors reviewed the outage planning and preparation performed by the licensee, including:
additional staffing, special training, increased equipment suppltes, and job related health physics consideration During the outage, the station's radiation protection group has been augmented with four station chemistry technicians who have been qualified as junior RSTs, two contract dosimetry clerks, and 66 contract RSTs (consisting of 52 senior and 14 junior technicians).
Nearly half of the contract RSTs were employed by the licensee during previous outages; the high rate of returnees and high percentage of senior RSTs appear to be indicative of a reliable contract RST staf The inspectors verified that those technicians not meeting ANSI Nl8.l-1971 selection criteria were not providing radiition protection coverag~ with prope~ supervisio The outage radiation protection program was also enhanced by.contract workers who provided decontamination, laundry, and respirator cleaning service Preoutage _special training provided to station and contract workers includes mock-up training for certain high exposure work, ALARA briefings for each work group, and RWP program trainin The inspectors also discussed the training program* with the RSD Training ALARA Coordinator No problems were noted in this are The supplies of portable survey instruments, portable ventilation equipment, respiratory protection equipment, and protective clothing appear adequate for the outag Evidence that job planning and preparation is influenced by radiation protection includes containment decontamination and shielding prior to allowing outage work to begin, and radiation protection and ALARA participation in all planning and outage meeting No violations or deviations were identifie.
Training and Qualifications of New Personnel (IP 83750)
The inspectors reviewed the education and experience qualifications of contract radiation protection personnel and training provided to the Licensee selection of contract Radiation Protection Technicians includes review of the technicians* resumes to determine conformance to ANSI NlB.1-1971 criteria for responsible technician Resumes of selected contract Radiation Protection Technicians who have worked at the station during the current outage were reviewed by the inspector The majority of technicians app~ar to meet or exceed the technician selection criteria in ANSI N18.1-197 Those not meeting ANSI Nl8.1-1971 selection criteria appear to have training and experience commensurate with their assigned
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- duties; the licensee met their goal of 80 percent of the contract technicians meeting ANSI Nl8.l-1971 criteria. After selected technicians arrive onsite, they are required to complete general employee and site specific training, three days of -radiation protection procedures training', and on-the-job task training and practical factors evaluation Following the procedures training, each contracted technician must pass a written examination on radiation protection procedures and policies and practical problem-solving; a score of 70 percent is require The majority of the examination questions related to station procedure and policies; problem solving questions are limited
'but appeared to be moderately difficul Inspectors selectively reviewed lesson plans, training modules, the procedures selected for the reading list, and training and exam records; no problems were note No violations or deviations were identifie.
External Exposure Control and Personal Dosimetry (IP 83750)
The inspectors reviewed the licensee 1s external exposure control and personal dosimetry programs, including:
chahges in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine needs; planning and preparation for maintenance and refueling tasks; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program'
implementatjon weaknesse The licensee 1 s dosimetry system remains essentially as discussed in Inspection Report No. 50-255/8802 Whole body dose received during 1988 through September 30 was about 86 person-re Total person-rem received during 1988 was about 73 Licensee representatives reported that there were 198 personal contamination events (PCEs) in 1989 through October Only three of these events were hot particles-which required skin dose calculations in accordance with licensee procedures; none of the calculated skin doses approached 10 CFR 20 limit No v{olations or deviations were identifie.
Internal Exposure Control (IP 83750, 83725)
The inspectors reviewed the licensee 1s internal ex~osure control ~nd assessment programs, including:
changes to facilities, equipment, and procedures affecting internal exposure control and personal exposure assessment; determination whether respiratory equipment, and assessment of individual-intakes meet regulatory requirements; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-iden~ification and correction of program implementation weaknesse The licensee 1 s respiratory protection program and MPC-hour accountability and tracking programs remains essentially as described in Inspection Report No. 50-255/8802l(DRSS).
During July 1989, the licensee began use of a stand-up whole body counte The previously used counters remain operational and could be used if neede According to the licensee, the stand-up counter performs a count in less time than the previously used counter An inspector selectively reviewed the results of whole body counts, ~onducted during 198 Several follow-up counts on persons with elevated initial counts were necessary to determine existence of-body burdens and provide information for MPC-hour calculation When calculated in accordance with the licensee's proced~res and cal~ulational methods, there is no indication that the 40 MPC-hour control measure presented in 10 CFR 20.103 was exceeded; the licensee's MPC-hour determination methodology is further discussed in Section No violations or deviations were identifie.
Control of Radioactive Materials and Contamination (IP 83750, 83726)
The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of revi~w and dissemination of survey data; ~nd effectiveness of methods of control of radioactive and contaminated material The inspectors selectively reviewed records of routine and special radiation and contamination surveys conducted during the outage to dat All surveys, routine and special, are reviewed by the duty HP for completeness and any unusual condition No problems were identifie As noted in Section 4 of Inspection Report No. 50-255/89025(DRSS), the licensee has significantly reduced the number of personnel contamination events (198 PCEs in 1989 through October 7, compared to 1471 PCEs in 1988)
by increasing the decontamination staff, improving laundry services, use of better protective clothing* (PC), and improved radiation worker practice Although the number of PCEs will be much lower in 1989 (compared to 1988),
the licensee is unlikely to accomplish the annual goal of 208 PCEs because of the greater than expected PCE rate during the outag The licensee attributes the app-arently excess outage PCE rate in part,- to poor radiation practices and less effective step-off-pad (SOP) m6nitoring of worker radiation practices during the night shift, high levels of contamination in containment, and spread of contamination when internally contaminated systems are breache The licensee stated that these root causes are being addressed by improving night shift SOP monitoring, plans to reduce contamination in containment and the auxiliary building by use of strippable paint and application of easy-to-decontaminate coatings to floor and other surfaces, and consideration of various internally contaminated system cleanup techniques.*
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The.auxiliary building decontamination effort continues to be effectiv By the end of*September 1989, only 23 percent of the floor area remained contaminated; the 1989 goal is 20_percen The success of this effort is due mostly to the doubling of the permanent decontamination staff and i~plementation of an effective leak reduction progra The decontamination staff was sufficiently augmented during the outag The elimination of the onsite. laundry facility has allowed the licensee to use the additional free space in the auxiliary building to reconfigure and expand the access control facility to enhance contamination contro Contamination control s~ould also be enhanced when the auxiliary building floor is coated with a protective layer of easy-to-decontaminate material (scheduled for completion in February-March 1990).
Although the licensee has made significant progress in reducing the number of PCEs, continuing management attention appears appropriate to further reduce the PCE rat This matter was discussed at the exit meetin No violations or deviations were identifie Maintaining Occupational Exposures ALARA (IP 83729, 83728)
The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA including changes in ALARA policy and procedures, ALARA considerations for maintenance and refueling outages, and establishment of goals and objectives and effectiveness in meeting the Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of programmatic weaknesse The inspectors reviewed documentation relating to ALARA planning for the outage, detailed estimations of doses expected from the current outage and for the rest of 1989, and estimations of actual doses received during current outage tasks compared to doses received during previous similar task Review of this documentation and discussion with ALARA personnel indicate that the station ALARA progra~ is effective and continues to improve performance, and that significant dose-savings may be attributed to those efforts..
Weaknesses in the ALARA program and the need to develop a comprehensive radiation source reductio~ program are discussed in Section 13 6f Inspection Report 50-255/88021(DRSS).
Recent licensee progress in correcting these weaknesses are discussed in Section 3 (Open Item No. 255/88021-05) and Section 4 of Inspection Report N ~255/89025(DRSS).
During the current outage, the licensee has implemented the source reduction program by the use of hydrogen peroxide addition to reduce primary coo 1 ant activity during shutdown, primary coo 1 ant and spent fue 1 pool filter upgrades, more effective use of the letdown demineralization system and continuation of the hot spot removal program (including containment hot spot identification).
Areas that appear to warrant continued management attention include support for more extensive source reduction techniques such as system chemical decontamination, cobalt inventory/replacement, and removal of containment hot spots as appropriat *7
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c The licensee estimates that the cumulative personnel dose was about 223 p~rson-rem on October 30, 1989; the 1989 goal is 400 person-re A review of detailed task projected doses and discussions with the ALARA Coordinator indicate that the current annual goal is consistent with the work activities planne Although the licensee has made initial progress
~egarding the radiation source term reduction program and the personne1 radiation exposure reduction goals, there are some aspects of the program (as stated above) that apparently need more aggressive management attentio This matter was discussed at the exit meetin *No violations or deviations were identifie.
Audits and Appraisals (IP 83750)
The inspectors reviewed reports of audits and appraisals conducted for or by the licensee including audits required by technical specification Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse The inspectors selectively reviewed portions of the QA auait and surveillance reports for 1988 and to date in 198 The licensee's QA audit/surveillance program* appears adequate to assess technical performance, compliance with requirements, and personnel training/
qualification relating to the radiation protective progra The QA auditors assigned to review this functional area appear to have the necessary expertise.and experience prerequisite Interviews with appropriate licensee personnel indicate that responses to audit/
surveillance findings are generally thorough, timely, and technically soun *
Licensee responsiveness to QA monthly surveillance findings regarding PCEs and poor radiation worker practices have been largely responsible for the recent reduction of PCE These surveillan~es were changed to a quarterly frequency after the PCE rate greatly reduced prior to the current outage; however, because the PCE rate increased significantly during the outage, so did the surveillance frequenc The surveillances continue to identify root causes for PCEs which are more definitive than the conclusions of PCE investigations conducted by RSTs; this may indicate that improvements are needed in the PCE investigations, tdentification of root causes, PCE trend analjsis, and corrective action No violations or deviations were identified by the inspector.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on November 9, 1989, and by telephone through November 21, 198 The inspectors summarized the scope and findings of the inspectio The inspectors also discussed the likely
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informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not.identify any such documents or processes as proprietary.
. The following matters were discussed specific~lly by the inspector Program strengths noted during the inspection included the reconfiguration of the access control facility to enhance contamination control (Section 10) and initiation of a comprehensive radiation source reduction program (Section 11). Matters that need continuing licensee attention include efforts to reduce the number of personnel contamination events (Section 10) and to reduce personnel radiation exposure (Section 11).
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