IR 05000255/1990028

Insp Rept 50-255/90-28 on 901015-29.Violations Noted.Major Areas Inspected:Radiation Protection & Training Programs Re Organization,Management Controls & Training,Audits & Surveillance,External Exposure Control

ML18057A578
Person / Time
Site:	Palisades
Issue date:	11/08/1990
From:	Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18057A577	List: IR 05000255/1990028 ML18057A576
References
50-255-90-28, NUDOCS 9011190235
Download: ML18057A578 (17)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/90028(DRSS)

Docket No. 50-255 *

License No. DPR-20 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~15-29, 1990

~&1 A. W. *Markley 01...-

Inspector:

Accompanying Inspector:

Approved By:

T. J. Kozak wW&1~

Radiological Controls and Emergency Preparedness Section Inspection Summary

,,/al.lo Date Inspection on October 15 - 29, 1990 (Report No. 50-255/90028(DRSS))

Areas Inspected:

Special, unannounced inspection of the radiation protection and training programs, including: organization, management controls and training; audits and surveillances; external exposure control; internal exposure control; control of.radioactive materials, contamination and surveys; and maintaining occupational exposures ALARA (IP 83729).

Included in this inspection was additional follow up for a seri-es of nonconforming activities identified in the General Employee Training program (IP 93702).

Results:

Based on additional inspection efforts and information gathered, the apparent training program violations identified in Inspection Report 50-255/90019(DRSS) are superseded by the apparent training program violations

• identified in this report:

falsification of training records and alterations of test results (Section 4); failure to provide instruction on precautions, procedures and uses of protective equipment to minimize exposure to radioactive materials and radiation (Section 4); and failure to provide an adequate indoctrination and training of contract training instructors (Section 4).

An unresolved item associated with a skin overexposure due to a hot particle was identified (Section 6).

90111902~:5 F'DR A:OOCK

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9(11109 (:15000255 F'DC

Weaknesses were identifi~d in the areas of General Employee Training program administration (Section 4), contamination controls.(Section 8) and licensee follow up on identified concerns (Section 5).

Strengths were identified in the following areas:

outage housekeeping (Section 11); outage progress (Section 11); and a cooperative work environment in which radiation protection appears to have sufficient control of outage

~ctivities (Section 11).

DETAILS Persons Contacted

• E. Bogue, ALARA Coordinator

• G. Cheeseman, Quality Assurance

• J. Fontaine, Senior Health Physicist

• 1. K. Haas, Radiological Services Manager

• L. Kenaga, Health Physics Superintendent

• 1. J. Kuemin, Licensing Administrator

• M. Lesinski, SGRP Radiation Protection Manager

• K. Marbaugh, SGRP Quality Assurance Superintendent

• R. Orosz, Engineering and Maintenance Manager*

1. W. Roberts, Licensing Staff Engineer

1. P. Rigozzi, Training Supervisor

1. D. Rogers, Training Administrator

1. G. Slade, Plant General Manager D. VandeWalle, Safety and *Licensing Director

• .J. Werner, SGRP Qua 1 ity Assurance

• J. Heller, Senior Resident Inspector

1. J. Hopkins, Resident Inspector

The inspectors also interviewed other licensee and contractor personnel during the course of the inspection.

• Denotes those present at the interim exit meeting on October 17, 1990

1. Denotes those present at the exit meeting on October 29, 1990. General This inspection was conducted to review aspects of the licensee's radiation protection and training program The plant's support of the Steam Generator Replacement Project (SGRP) in the areas of radiation protection and radioactive material control was evaluate Included in this inspection was a follow up of outstanding items in the areas of General Employee Training (GET), contract radiation protect1on (RP)

technician training and* instructor certification. The inspection included tours of radiation controlled areas and containment, observations of licensee activities, review of representative records and discussions with licensee personne Management Meeting (IP 30702)

On October 3, 1990, a management meeting was held at the Palisades Nuclear Generating Plant with members of the licensee's plant, radiological services and Steam Generator Replacement Project (SGRP) managemen This meeting was conducted to discuss the licensee's self assessment of the radiological controls area and to obtain feedback from the licensee

regarding the NRC ALARA team inspection that was conducted during May 199 *

The licensee opened the meeting with a status summary of SGRP activities, including experience with personnel radiation exposure and contamination event The licensee then presented information regarding its experience in performing INPO style performance based self assessments, goals that were established for the radiological controls self assessment and a description of the self assessment proces The licensee then provided a summary of the major issues that were identified during the self assessment and plans for implementing corrective actions for the identified weaknesses and improvement item The licensee then briefly discussed issues identified during the ALARA team inspectio However, the licensee was not prepared to provide feedback regarding the ALARA team inspection results compared to the findings made by the licensee's se-if assessment in ALAR The licensee committed to provide NRC management with a correlation analysis of the self assessment findings and the NRC ALARA team inspection result In addition, the licensee committed to provide NRC management with a copy of the radiological protection self assessment repor.

Apparent Training Program Violations (Ip 83729, 93702)

Based upon the results of an earlier inspection of problems identified in the General Employee Training (GET) program at Palisades, the NRC determined that additional inspection efforts were necessar The following provides a summary of issues identified in Inspection Report 50-255/90019(DRSS) and the findings of the additional inspection effort Event Summary for August 1990 Apparent Violations On August 31, 1990, the licensee determined that a contract training instructor had willfully failed to provide the required practical factor portion of General Employee Training to twenty contract radiation protection technicians (eight of whom had been subsequently authorized access to the radiologically controlled area (RCA)) and had falsely documented that this training had been performe The licensee indicated to the inspectors that the training instructor had stated to them that the instructor understood that waivers for practical factor performance were not allowe The licensee implemented corrective actions which included retraining of affected personnel and resulted in the resignation of the instructor in questio This resulted in two apparent violations as described in Inspection Report 50-255/90019(DRSS) which are superseded in this repor Licensee's Investigation of August 1990 Training Falsification The licensee's investigation consisted of reviews of class documentation, interviews with the technicians who attended the classes and an interview with the instructor in questio The licensee did attempt to evaluate the scope of the problem; however, the problem was defined only in terms of instruction of the required

practical factor The licensee did not evaluate the circumstances or conditions that may have contributed to the instructor's improper performanc Nor did the licensee evaluate the integrity and quality of other documentation for which the instructor was responsibl Rather, the licensee's evaluation focused on whether or not the instructor had falsified training record NRC Interview with Instructor in Question On October 25, 1990, two NRC personnel interviewed the former instructo The former instructor willingly acknowledged signing the documentation indicating that the c1ass participants had completed the practical factor.training, but only as a means of indicating that the trainees were waived from the trainin The instructor stated that since all the students were ANSI qualified technicians, and that further in depth training would be provided, it was the instructor's professional judgement that all of the students could be waived from the trainin The instructor also stated that had any of the students not been ANSI qualified or had similar experience, that the practical factor training would have been provide The instructor also denied having any knowledge that practical factors training was required to be given, and could not be waive *

The contract training instructor was hired by Consumers Power Company as a 11Training Engineer 11 in January 199 The instructor was hired initially to conduct Health Physics trainin At a later date (approximately February or March 1990) the instructor was requested to also conduct General Employee Training (GET).

Certification to conduct this training included teaching of a course segment while being observed/evaluated by another individual already certified to conduct the training, and then being certified upon completio The instructor stated that they neither received nor were informed of any procedures governing GE The instructor had asked another trainer if any procedures were available and were told not to their knowledg The instructor claims to have looked for relevant material in the training library and was unable to find any documentation pertinent to the GET trainin At no time was the instructor either informed verbally or provided with documentation that indicated that practical factors training could not be waive The instructor pointed out that the practice of waiving practical factors training for ANSI qualified or otherwise experienced technicians is common industry practice, and there was no reason to believe the situation was different at Palisade In addition to the two classes taught by the instructor in August 1990, the instructor also taught one or possibly two GET classes in the Spring of 199 It was stated in the October 5, 1990 inspection report that the licensee's investigation was unable to determine if the practical factors training had been conducted or waived for the Spring 1990 classes taught by this instructor; only

that it was not conducted for the August 1990 classe The instructor stated that the practical factors training was not performed for all the students in the Spring GET classes that the instructor had conducted, and that some of the students had in fact been waive The instructor also stated that a second instructor had been hired to conduct GET trainin The first class this second instructor taught was during the same week the first instructor was teaching the second of the two classes that were taught in Augus After the first instructor was confronted by the licensee for falsifying the records, the first instructor told the second instrucior to make sure that the practical factors training port~on of the GET class was actually conducte It was the opinion of the first instructor that had this not been brought to the attention of the second instructor, the second instructor also would have waived the practical factors portion of the GET trainin One inconsistency that could not be explained was that some of the records that the instructor had signed to indicate that a student had 11passed/waived 11 the training, showed specific portions as being unsuccessful, with demerits assigne The document used consisted of a single sheet form of multiple line items that addressed the various facets of the practical factors trainin Following each line item was a place to 11 check 11 whether the student had. successfully or unsuccessfully demonstrated that item, and if unsuccessful, a place to assign demerit If the.total number of demerits exceeded a specific value, the student faile Failure meant repeating the training until it could be successfully performe The instructor

• signed at the bottom of each of the forms, with one form per student, after either 11 checki ng off" all the items as successful, *or 11checki ng off 11 the first item and drawing an arrow down through the rest of the

• item The instructor deni!d having assigned demerits, but had no explanation as to how or why demerits were assigne The instructor did state that there were four or five technicians present who were assigned to the training facility by the Health Physics Supervisor to support the training effort, who had helped her fill out the form None of these technicians were given any directions as to how to fill out the for When asked if it was possible that one of the technicians could have given the practical factors training without her knowledge, the. instructor was sure could not have happene The instructor acknowledged signing all the forms, even those that were fi 11 ed out by the technician When questioned about a motive to not conduct the practical factor training, the instructor stated that there was non Because the instructor was being paid by the hour, and the training would have taken about one and one half hours per class to complete, the instructor would have made more money by providing the trainin *

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NRC Interviews with GET Training Staff On October 29 and 30, 1990, interviews were conducted with members of the contract training and licensee training department personnel by two NRC personne The following summarizes the findings from this effor The contract training staff was certified to conduct training at Palisades Nuclear Generating Plant in accordance with the licensee's training department procedure This was comprised of a resume review and acceptance, either attendance in a class by the instructor of the training to be taught or a demonstration of training capabilities, and then conduct.of training under observation and approval of the training section hea The contract instructors were provided applicable lesson plans, transparencies, instruction on class package documentation and student handout In addition, the instructors were provided with updates and revisions to lesson plan Upon certification, the licensee expected that the instructors would take the initiative to ensure that all materials and documentation used to implement training activities were curren However, the licensee did not provide these instructors with training department procedure The licensee's training department personnel insisted that the contract instructors did not need a knowledge of these procedures to be able to perform their assigned instructor's dutie The licensee also stressed to the inspectors that had the training department procedures been provided to the former instructor, it would not have altered the former instructor's action The training department procedures established administrative controls for the conduct, implementation and documentation of training activities. These administrative controls included provisions for granting waivers for the performance of training, handling difficult situations encountered in the classroom and defined responsibilities of the instructor All instructors interviewed indicated that they had not been required to read the training department procedures nor were they provided these procedure All of the instructors indicated that it was unusual that instructors were not required to read training department procedure Other reactor sites had required them to be cognizant of these procedure The contract training supervisor indicated that he had to request copies of the training department procedures (received approximately three months ago) and still does not have a complete se These instructors also indicated that they did not receive copies of revised training department procedure The contract training supervisor indicated that he ensures that his instructors receive revised lesson plans and revised forms that are included in the class package The former instructor did not work with these contract instructor Instead, the former instructor worked out of an office in the protected area and was not on

distribution for revised training forms and lesson plan The contract training supervisor also indicdted that the former instructor already possessed class package documentation for the courses that the former instructor was scheduled to teac Presumably, this would explain the use of outdated forms for class documentatio The forms that the former instructor used were of proper revision for classes that the former instructor taught during the Spring of 199 The inspectors noted an additional weakness in the training program certification proces The instructor who performed certification evaluations was also a contract instructor who has been onsite since the Fall 1989 outag This instructor was trained and certified in the same manner a~ the other contr~ct training instructor This instructor indicated that he was not instructed to read the training department procedures until he became responsible for certifying other instructor Summary of August 1990 Apparent Violations This listing of apparent violations supersedes the training program violations that.were identified in Inspection Report 50-255/90019(DRSS):

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The licensee maintains that the instructor was aware of the

• requirements to perform the practical factors portion of GET training and acknowledged the same to the license The instructor maintains that this requirement*was not communicated and that this requirement was not acknowledge Disregarding this difference of opinion, twenty individuals did not receive the required practical factors portion of GET, eight of whom were subsequently authorized a."ccess :to the RC Failure to provid~ instructions to personnel on the precautions and procedures used to minimi..ze exposure to radioactiv materials and radiation and on the ~roper use of protective equipment is an apparent violation of 10 CFR 19.12. (No. 255/90028-01)

The former instructor acknowledges that the inaccurate records were knowingly signed, but not with an intent to deceiv Failure to maintai~ accurate records of information which the NRC requires to be mai.ntained is an apparent violation of 10 CFR 50.9(a).

(No. 255/90028-02)

The licensee failed to provide cont-ract instructors, inc'luding the former instructor, with appropriate training on training department administrative controls and *procedure This included procedures that delineated the requirements for waiving training requirement Failure to provide indoctrination and training to as~ure that a suitable profi~iency is achieved and maintain~d is an apparent violation of 10 CFR 50, Appendix 8, Criteria II. (No. 255/90028-03)

It is noted that an instr~ctor at some other facilities can exercise judgement regardi*ng the qualifications and needs of specific individuals or groups of individuals to perform/waive practical

factor training. It is also noted that contract radiation protection technicians are many times waived with respect to performance of general employee/basic radiation worker practical factor trainiri Event Summary for October 1990 Test Alterations On October 4, 1990, a SGRP quality assurance (QA) team commenced a surveillance of contract radiation protection (RP) technician training and qualification It was noted by the QA team that the class package documentation for the classes of August 20 and 27, 1990 were not compile This was apparently due to the sudden departure of the former instructo During the course of this surveillance, numerous grading.errors were identifie Neither a correct answer key nor copies of the tests -given were available to the QA tea Some of these errors were due to an inappropriately sized overlay answer key (copied onto the overlay at 102%) and others were due to poorly worded questions for which credit was given but not adequately documente These errors were made known to the SGRP RPM on October 5, 199 During this discussion, the SGRP RPM was provided copies of raw QA notes and copies of original exams that were in questi~n regarding*

pass/fail status. The SGRP RPM indicated that he would try to obtain correct answer keys and copies of the exams from the former instructo Discussions were then held between the SGRP RPM and the Palisades Radiological Services department cognizant for RP training (Senior Health Physicist). It was agreed to bring back the former instructor over the weekend to provide compilation of the class package documentation, provide correct answer keys and provide copies of ori~inal exams give The Senior Health. Physicist allowed the former instructor to recheck the original exams* but failed to provide constant supervision of the former instructor during this tim The QA survei 11 ance *team subsequently compared the regraded ori gi na l exams with their copies of the exam On October 8~ 1990, the comparison of one RP technician's annotated exam with the copy made on October 4, 1990, indicated that the answer to one question had been change The SGRP and Plant management were informe The licensee commenced an investigation of this eve~~ on October 9, 199 *As a result of the investigati~n. three additional exams were identified that had answers change Of the four c1ases, only one resulted in the passing of an individual *who had previously failed.*

However, the licensee's investigation was unable to identify those responsible for the test alteration As a result of the grading errors and tampering with examination results, the licensee regraded all exams that were graded by the former instructo This regrading, including rejection of poorly worded questions, resulted in seven prequalification examination

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failures, eight qualification examination failures and a fitness for duty (FFD) examination failur Supervisors were notified and the radiation protection (RP) technicians who failed the prequalification and qualification examinations were restricted from independent wor Work restrictions remained in effect until RP technicians were successfully retested and evaluations of their performance were made by their supervisor One individual failed to pass the screening exam retest; however, a special evaluation of this case cleared the individual to continue normal work activit The individual who failed the FFD exam was restricted from protected area access until he successfully passed the FFD retes Licensee Identified Cause of Test Alterations The licensee identified root cause of the test alterations was the failure* of the Radiological Services Department (RSD) to implement the testing, grading and record security standards of the Nuclear Training Departmen The licensee also indicated that the former instructor appeared not to have assumed the obligations of these normal standards or accepted the importance of accurate and traceable training record The licensee also indicated that RSD personnel who handled the training records were familiar with security requirements but had no reason to question their strict application to the former instructo October 1990 Apparent Violation The licensee is required to maintain records of training and qualification of personne Alteration of examination results is a failure to maintain accurate records of information which the NRC requires to be maintaine This is another example of a previously identified apparent violation of 10 CFR 50.9(a). (No. 255/90028-02)

Three apparent violations were identifie.

Audits, Surveillances and Self Assessments (IP 83729)

The inspectors reviewed the results of Quality Assurance audits and surveillances conducted by the licensee since the last inspectio The inspectors also reviewed the extent and thoroughness of the audits and surveillance The inspectors also reviewed the licensee 1 s event identification programs and corrective actions that were taken in response to these event Audits and Surveillances A separate SGRP quality assurance organization has been established to perform audits and surveillances of various SGRP activitie The inspector reviewed the quality assurance audits and surveillances of the Project activitie These included surveillances of contamination control practices, training and qualification of contract RP technicians, SGRP mockup training and steam generator 11A11 main steam line cuttin No significant radiological problems were note *

Plant tour reports did identify a number of problems with radiological posti~gs, including high radiation areas, high contamination areas and potential airborne areas; setup and placement of contaminated area access points; housekeeping and control of respirator The most significant item was a failure to post caution and warning signs on lines tied off to the reactor cavity wal These lines were tied to such things as lights, hoses and incore detector The licensee responded in a timely manner to take corrective actions to resolve deficiencies identifie The audit report resulted in two observations and no finding The observations were related to implementation of SGRP program requirements that involved requisite reviews and approvals of project activities and to estimates made of projected radwaste quantitie Event Identification and Corrective Actions The inspectors reviewed plant deviation reports, radiation incident reports and radiological deficiency report In general, event identification was consistent with regulatory and procedural requirement The determination of corrective actions was usually adequat However, the investigation of the training records falsification event revealed numerous weaknesses in the licensee's evaluation of the event and follow up activities. These are discussed at length in Section 4 of this repor In addition, a review of radiation incident reports (RIRs) indicated that the licensee has a number of reports from 1989 that have not been closed ou The licensee indicated to the inspector that some of these RIRs involved long term actions such as trainin This issue, outstanding RIRs, had been specifically discussed with the licensee by the inspector during the previous inspection in August 1990. It should be noted that, with the exception of the last 3-4 months, most of 1990's RIRs have been closed ou The NRC expects its licensees to take timely corrective actions to resolve identified concern Given the poor evaluation and follow up of the training program events and the lack of progress to closeout outstanding RIRs, licensee performance in this area appears to be wea No violations or deviations were identifte One programmatic weakness was identified in the area of corrective actions implementatio.

External Exposure Control (IP 83729):

The inspector reviewed the licensee's external exposure control and personal dosimetry program, including:

changes in the program, use of dosimetry to determine whether requirements were met, planning and preparation for maintenance and refueling outage tasks including ALARA considerations and required records, reports and notifications.

,.

• Personnel Dosimetry Program Personnel exposure records for current and past licensee and contractor employe~s were selectively reviewed for completeness, accuracy and inconsistencie In addition, reporting of exposure information was reviewed for timelines No problems were note The inspectors discussed the implementation of the electronic dosimetry system with the license The inspectors were concerned with the capture of exposure information during computer system crashes and reviewed the licensee's experience and records for two system crashes that occurred on September 21, 1990 and on October 12, 199 The licensee indicated that the computer is rebooted and that the exposure information is then manually entered to update the exposure record In addition, the licensee indicated that the electronic dosimeters also had a battery backup that was capable of storing up to 1,200 reads/records which could then be downloaded into the computer syste No problems were note The licensee has adopted the administrative exposure control system as discussed in Inspection Report 50-255/90019(DRSS).

As reported by the licensee, plans have been made to proceduralize this system after the SGRP outag Potential Hot Particle Overexposure On October 12, 1990, a worker exited the RCA after performing a decontamination of the spent fuel pool heat exchanger end bell The PCM-18 contamination monitor detected a 0.7 uci particle on the worker 1 s fac The individual had worn a respirator and the hot particle was found pressed into the worker 1 s face in the respirator seal are The individual was decontaminated and the hot particle was captured, analyzed and measure The initial dose assessment indicated that a dose to the skin of the whole body of approximately 9 re The licensee 1 s investigation is continuing and this will be further evaluated during a future inspectio (Unresolved Item 255/90028-04)

No violations or deviations were identifie One unresolved item was identifie.

Planning and Preparation (IP 83729)

The inspector reviewed the outage planning and preparation performed by the licensee, including:

additional staffing, special training, increased equipment supplies and job related health physics consideration Planning and preparation for this project have been discussed in Inspection Report 50-255/90019(DRSS).

The inspectors reviewed the status of the radiation protection and radioactive material control planning implementation during SGRP activitie Video equipment is being used to support radiological coverage and to provide general and worker informatio A monitor station has been setup in a visitor area near the administrative building entranc This station provides coverage of the

upper level of containment and is controllable by the use of a control panel at the monitor statio The controls include pan and zoom function Another monitor station is located in the upper level of the containment access facility (CAF)~ This station monitors various areas of the containment including the steam generator pipe cut area This station has the same features as the aforementioned one; however, an override function prevents camera movement when the camera is used for radiological coverag The additional counting room is functional and being used for air ~ample results determination The containment access facility is functional and appears to be adequately handling the traffic flo Communication equipment was observed in use to provide coordination of radiation protection coverage activitie No violations or deviations were identifie.

Control of Radioactive Material (IP 83729)

The inspector 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 review and dissemination of survey data; effectiveness of radioactive and contaminated material control Portable Survey Instruments The inspectors verified by a review of records, discussions with licensee personnel, and tours of operational areas, that the supply, maintenance, calibration and performance checks of survey and monitoring instruments were adequat No significant problems were identifie Personnel Contamination Events The inspectors reviewed personnel contamination trending reports, summaries and analyses for the SGRP/refueling outage from September 15, 1990 to dat Prior to the containment tour, all 62 contamination events were reviewe The review indicated that poor work practices and poor ant1-contamination undress techniques were major causes of personnel contamination An unusually high number of clean area contaminations were also note Given the high number of recent personnel contaminations, a main objective of the containment tour was to observe contamination control work practice The inspectors observed the following:

Two workers inside the containment, one of whom was an RP technician, were observed wearing anti-contamination clothing

. improperl Both worker's hoods were unsealed and wide ope The RP technician was observed with his coveralls unzipped to the wais As the RP technician's supervisor indicated, GET allows employees to open their coveralls to obtain items from the.insid However, GET makes no provision for leaving the

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hood unseale The inspectors noted that, at the least, the RP technician did not follow procedure and was setrting a bad example for other worker The inspectors also noted to RP personnel that adequate supplies of pens and time keeping devices should be maintained to obviate the need to remove protective clothing in a,contaminated are Several workers removed respirators upon exiting a potential airborne/highly contaminated area in the vicinity of the B steam generator pipe cut No b~gs or receptacles were available in which *to place the potentially contaminated respirator The RP technicians instructed the workers.to hand carry the respirators out to the containment egress area.. One worker was observed to place his respirator on the RP station tabl The RP technicians did not notice this action and, as a result, did not perform surveys to ensure that no contamination was sprea As the inspectors removed anti-contamination clothing*in the CAF undressing area, it was noted that undressing instructi6ns were presented in a somewhat confusing manne At no time wis the entire sequence presented on one sig Rather, these instructions were pr6vided in a several step, multiple sign forma Although all steps were eventually covered, they were not presented in a concise, easily understandable manner~ This may contribute to the high number of.personnel contaminations that were attributed to improper undressing techniques..

Numerous workers were observed scratching/rubbing their faces, adjusting their safety glasses, etc. with potentially cbntaminated outer rubber glove Given the numbers of contamination~ experienced and poci~ work practices by both workers and RP technicians that were obs~rved and contaminations associated with clean area work, licensee performance in the area of contamination controls appears to be wea No violations or deviations were identifie A programmatic weakness was identified in the area of contamination controls; Maintaining Occupationa*1 Exposures ALARA (IP 83729):

The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: ALARA group staffing and qualification; changes in ALARA policy and procedures, and their implementation; ALARA considerations for planned, maintenance and refueling outages; worker awareness and involvement in. the ALARA program; establishment of goals and objectives, and effect1veness in meeting the Also reviewed were management techniques, program experience and corre~tion of self identified program weaknes~e The inspector newly revised The inspector containmen reviewed selected records and ALARA planning documents and procedures for the plant and SGRP ALARA planning effort discussed the ALARA program with several workers in the These individuals were performing a variety of work

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activities, from rigging out of the iieam generator elbows to various interference removal activiti~~-

The workers knowledge of their radiation work permits (RWP) and the ALARA requirements.for their jobs was inconsisten Some workers had a good understanding of their RWP, radiological conditions and the ALARA requirements; however, others did not seem to know much more than their RWP numbe This was discussed at length with the licensee following the *tours of containmen Personal dose and contamination performance for CY1990 to date is as follows:

Total* exposure for plant ~ctivities to date was 270.8 person-re Total contamination events for.plant activities to date was 18 Total exposure for SGRP activities to date 226 person-re Tdtal cont~mination events for SGRP activities to date was 12 *Total expo$ure for Palisades to date was 496.8 person-re Total contamination events for Palisades to date wa~ 30 No violations or deviations were identifie.

Safety Injection and Refueling Water Tank Leakage (IP 93702)

On October 8, 1990, following a refil1 of the safety injection and refueling water (SIRW) tank from the reactor cavity, it was noted that the SIRW tank was experiencing an approximate 25 gallon per hour lea This Wi3.S discovered by the leakage cif water into the auxiliary building and the spread of contaminatio The licensee commenced investigations and radiological survey Efforts ~ere immediately begun to contain and

. collect the leakage...

The w&ter.that leaked. from this tank became trapped between the layers of roofing material. *Monitoring efforts to date indicate that there has been no release of radioactive material from this tank, other than leakage into the auxiliary building belo Currently, it appears that the insulating material below the roof layers, comprised of sheets of volcanic ash, has dissolve This has resulted in an extremely thick slurry of watery sludge trapped between the roof layer The following informatibn describes the licensee 1 s ~urrent plans to

.resolve this problem from a radiological standpoin The roofing material will be removed and disposed of as radioactive wast The sludge will be drummed, de-watered and disposed of as radioactive wast The roof will then be hydrolazed, allowed to dry and a sealant will be applied to fix any remaining radioactivit The licensee will then build a:* large contamination containment tent around the tank i'n which access to the tank will be controlle The tank will then be cleaned, inspected, repaired and closed out.. The residual materials will be removed from the roof and disposed of as radioactive wast Finally, a new roof will be installe No violations or deviations were identified.

1 Plant Tours (IP 8372~

The inspectors performed several tours of radtologically controlled area These included walkdowns of containment buildin The inspectors observed the following:

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Radiation workers access and egress from the RCA; personnel use of frisking stations, portal monitors and electronic dosimetry were acceptabl Contamination monitoring, portable survey, area radiation monitoring instrumentation in use throughout the plant; instrumentation observed had been recently source checked and had current calibrations, as appropriat Posting and labeling for radiation, high radiation, contaminated and radioactive material storage areas; posting and labeling were in accordance with regulatory requirements and approved station procedure Housekeeping and material conditions for the level of work activities were generally adequat Problems were noted in the area of tool contro There were numerous examples of tools and small equipment strewn abo11t various work sites throughout the containment where no visible work activities were ongoin A clean area had been established in the upper containment to facilitate the setup of rigging equipment for removal of the steam generator This had minimized the contamination of clean equipmen Removal of the containment block/penetration and removal of the thermal shield were observed by the inspector Plans for monitoring of radiological conditions were reviewed and their implementation were observe No problems were identifie Outage performance appeared to be very goo The SGRP continued ahead of schedule, currently about 5-6 day Most major outage activities appeared to be well coordinated and sequenced with appropriate levels of suppor The working environment appeared to be characterized with a cooperative atmosphere that facilitated a sufficient level of radiological control of outage activitie No violations or deviations were identifie.

Exit Interview (IP 30703)

The inspectors met with licensee representatives (denoted in Section 1)

during the inspection on October 17 and 29, 1990, to discuss the scope and findings of the inspectio During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio Licensee representatives did not identify any such documents or processes ~s

• proprietar The following matters were discussed specifically by the inspectors: The apparent violations (Sections 4.e and i) Inspector concerns regarding the apparent skin of the whole body overexposure. (Section 6.b, Unresolved Item No. 255/90028-04) Inspector concerns regarding the apparent weakness of the corrective action implementation and contamination control program. (Sections 5.b and 8.b)

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