IR 05000255/1992020

Forwards Safety Insp Rept 50-255/92-20 on 920706-10.No Violations Noted

ML18058A995
Person / Time
Site:	Palisades
Issue date:	07/30/1992
From:	Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML18058A996	List: IR 05000255/1992020
References
NUDOCS 9208040251
Download: ML18058A995 (14)

Text

Docket No. 50-255 Consume~s Power Company *

ATTN:

Gerald General Manager**

Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway

• Covert, MI 49043

Dear Mr. Slade:

0.;c_,D I*

JUL 3 u 1992.

This refers to the routine safety inspection conducted by Mr.*. D. W. Nelson of this office on July 6-10, 1992, of activities at the Palisades Nuclear

. Generating Plant, authorized by NRC Provisitinal Operating License No. DPR-20

• and to the di~cussion of our findings ~ith members of your staff at the

con~lusion of the irispection.

.

..

.

.

.

The enclosed copy of our~inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures ~nd representativ~ records, observations, and interviews with personnel.

.

.

No violations pf NRC requirements were i denti fi ed during the c~urse of this i n*spect ion.

• In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed ins~ection report will be placed in the NRC Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Eri~losure: *Inspection Report No. 50-255/92020(DRSS)

See Attached Distribution:

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~ Nel son/cjb fM /L)/92 *

• ,'* *". i,...

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9208040251 920730 PDR ADOCK 05000255 G

• PDR

Sincerely, William Snell, Chief Radiological Controls Section 2 RII I J~nsen

~/;t

.

• • ****

~-

. Consumers Power Company Distribution:

cc w/enclosure:

David P Hoffman, Vice President Nuclear* operation~

P. M. Donnelly, Safety and Licensing Director

. DCD/DCB (RIDS}

OC/LFDCB Resident Inspector, Riii James R: Padgett, Michigan Public Service Commission Michigan Department of Public Health

.

. Palisades, LPM. NRR SRI, Big Rock Point.

2 JUL 3. v 1992.

U. S. NUCLEAR REGULATORY COMMISSION REG!Otf I l I

. Report No.. 50-255/92020(DRSS)

Docket No.. 50-255 Licensee:

Consumers Power Company

.212 West Michigan Avenue.

Jackson, MI 49201 Facility Name:

P~lisades Nuclear Generating Plant In~pection.At:

Palfsades Site, Covert, Michigan Inspection Conducted: * July 6-10, 1990. *

-of). s~

JJ

.Inspector: D~.~n *

(,..._.

Radiation Specialist

.*. Approved By:. w;W~ef

.*

Radiological Controls Section 2 Inspection Summary License No.

DP~-20 *

Date*

Date

. *..

• .* * *.... *

Inspectitin on July 6~10. 1990 CReport No. 5b-255/92020CDRSS))

Areas Irisp~cted: Routine unannounced inspection of the radiatidn protection,

• radwaste and transportation programs,.including: organization, management

.controls and training; ~udits,jnd appraisals; external exposure control; control of radioactive materials, contamination, and surveys; and maintainif'lg occupational exposures ALARA (IP 83750).

The inspection also included solid waste and transportation (86750).

Open items from past identified coricerns (92701) were also reviewed.

..

.*

• .

Results:

No viol~tions or deviations wer~ identified. The licensee's radiation protection program.appears to.be generally.effective in controlling radiological work and in protecting the public health and safety. *Strengths included the operational ALARA pro_gram, advanced radiation worker trainirrn, the reorganization of the radiological servi~es department (RSD), the job

• scheduling program, RSD staff stability, and the. radiation transportation

~rogr~m. Areas where improvement appeared to be merited included*the

• licensee's procedur_a 1 review process and i den ti fi ca ti on and documentation of corrective actions.

DETAILS 1. * Persons Contacted

• D. Anderson, Nuclear Performance Assessment

• . A. Clark, ALARA Program Coordinator

• .P. Donnelly, Safety and Licensing Director

• .M~ Grogan, Radioactive Materials Shipping Supervisor

• K. Haas, Radiological Services Department Manager

• J. Kuemin, Licensing Administrator

• D. Malone, Radiological Services Superintendent.

• M. Mennucci, Health Physics (HP) Technical Supervisor*

• . T. Neal,. HP Support Superintendent

• K. Schneider, Radiation Work Permit (RWP) & Planning S~pervisor

• J. Stu~deman, Duty HP Super~i~or

• J. Heller, Senior Resident Inspector The inspectors also interviewed other Licensee and contractor petsonnel*.

during the cqurse of the inspection.

• Denotes those present at the exit ~eeting on July 10, 1992.

2. * *

General Thi~ inspection was conducted t6'revie~ aspect~ of the licensee~~.*

radiation protection rad~aste/radioactive ~aterial shipping and.

transportation programs.

Included in this inspection was a follow~up. of

. outstanding items in the areas of radiation protection and radioactive w*ste management~ The inspection included tours of radiation controlled areas, auxiliary building, radwaste facilities, observations of licensee activities,.review of representative records and discussions with*

licensee personnel.

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• *

3.

Licen~ee Action oh Previous. Inspection Finding~ (IP 9i70ll (Open) Open ltem 255/91011-02. *.Untimely ih~~t of survey results into.

• radiation work permits (RWPs).

• This item will remain *open.

The licensee wrote a memo on January 21, 1992, addressing the issue of untimely input of surveys into RWPs., That inemo detailed three enhancements to"the program including:

requiring that all RWPs that need initial and/or confirmatory surveys du*e to

.

changes in radiological conditions be put on hold until the surveys ~re*

received,* reviewed and addressed in the RWP;. the Radiological* Services *

Department (RSD) Scheduler will incorporate int~ the 72-hour schedule *

• sufficient time to obtain the surveys needed for upcoming work; and RWPs

• will include the* requirement for additional surveys to begin work or if conditions change.

The memo did not set a time limit for redoing surveys if conditions change or for incorpotating new.surveys into RWPs.

In addition,* none of these enhancements were incorporated into adm~nistrative or HP procedures.

....

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1.

DETAILS Persons Contacted

• D. Anderson*, Nuclear Performance Assessment

• * A. Clark, ALARA Program Coordinator.

• P. Donnelly, Safety and Licensing Director

• M. Grogan, Radioactive Materfals Shipping Supervisor

• K. Haas, Radiological Services Department Manager

• J. Kuemin, Lic~nsing Ad~inistrator

• .

• D. Malone, Radiological Services Superinterident

• M. Mennucci, Health Physics (HP) Technical Supe~vi~6r

• T. Neal, HP Support Superintendent

• K. Schneider,* Radiation Work Permit (RWP) & Planning Sup~rvisor

• J. Stuedeman, Duty HP Supervisor

• J. Heller,. Senior Resident Inspector The inspectors also interviewed other Licensee and contractor pers6nnel during the course of the in$pection.

• Denotes those present at.the exit-meeting on July 10, 1992.

2. *. Genera 1 Jhis inspection was conducted to ~ev~~w aspe~ts of the licensee's

• radiation protection radwaste/radioactive material shipping and

.

.

transportation programs.

Included in this inspection was a follow-up of outstanding items in the areas of radiation protection and radioactive * *

waste manageme~t. The inspection included tours of radiation ~ontrolled areas, auxiliary building, radwaste facilities, observations of 1 icensee activiti~s, review of representative records and discussions with licensee ~ersonnel.

3... licensee-Action on Previous Inspection Findings CIP 92701)

(Open) Open Item 255/91011-02.

This item will remain open.

The licensee wrote a memo on January 21, 1992, address_ing the issue of untimely input of surveys into RWPs.

That memo detailed three enhancements to the program inc 1 ud i ng: * requiring *

that all RWPs that need initial and/or confirmatory surveys due to

..

changes in radiological conditions be put on hold until the surveys are received, reviewed and addressed in the RWP; the Radiological Services Department (RSD).Scheduler will incorporate into the 72-hour schedule sufficient time to obtain the surveys needed for Upcoming work; and RWPs will include the requirement.for additional surveys to begin work or if conditions change.

The memo did not set a time limit for redoing surveys if conditions change or for incorporating new.surveys into RWPs.

In addition, none of these enhancements were inco~parated into administrative or flP procedures.

{Closed) Unresolved Item 255/91022~02. The applic~tion of 10 CFR 50 Appendix B design criterl.a in the 10 CFR 50.59 analysis for the interim *

radioactive-waste storage facilities.

Based on further NRC review, it was deter~ined that the concerns addressed by this unresolved item were.additional examples of the violation for inadequate 50.59 ~eviews i~sued in Inspection Report No.

50-255/91022(DRSS)

(25~/91022-01).

Thi~ item is closed.

{Closed) Violation 255/91022-01.

Inadequate 10 CFR 50.59 analysis of the south interiin radioactive waste storage facility and the east radioacti~e waste proce~sing facility.

• The licens~e provided two responses to thii Violatibn, dated January 10, 1992 and April 15, l992.

The licensee performed ari analysis*

of the r.elease pathways for both buildings, installed area monitors and continuous air monitors. in.both buildings, installed fire alarms in both buildings, wrote procedures for surveying the buildings and had all monitor alarms wired into the control room via the telephone line~. *in addition, the lic~nsee installed a high efficiency particulate air (HEPA). filter system iri the. east processing building ~nd trained the *

radioa~ti~e wa~te supervisors in the requirements of performing a 10. CFR 50.59 analysis. These actions ~ere considered to be adequate.

This item is closed. *

• (Closed) Violation 255/92008-02.

The licensee failed to provide a 24 *

hour emergency respbnse/coritact telephone number on their shipping *

papers.

The 1 i censee has modified their 'protoco 1 so that all incoming emergency calls will be immediately routed to the control room.. Control room*

personnel have been provided with a set of instructions and a list of persorinel to contact if ~n emergency call is received. All effected personnel ha~e received training in dealing with a trans~ortation emergency and the training was documented. *This item is closed.

4.

Organization, Management Controls and Training CIP 83750)

The inspectors re~iewed the licensee's organizatiori and mana~ement

. controls for the radwaste and shipping and transportation programs, incl~ding:

cir~anizational structure, staffing, delineation of authority and management techniques used to implement the pro~ram and experience concerning self-identification and correction of p~ogram implementation weaknesses.

On June 1, 1992, the ~adi~logical Services Department underwent an extensive reorganization.

Under the Manager of the Radiological Services Department (RSD) the department was organized into four separate groups:. radiological services, health physics (HP) support, HP technical and the Radiation Protection Manager.

The ~adiological *

services wili be the ope~ational arm of th~ RSD and be responsible for.

the duty HPs, radioactive material and waste shipping, radioactive waste processing, radiationdecontamination, operational ALARA and scheduling.

HP support will be responsible for dosimetry, in_strument calib.ration, the RSD* hot lab, the Management Information System {MIS), respiratory protection, effluent monitoring and radioa.ctive materials control; HP technical will be responsible for emergency preparedness,_ projects (the n~w 10 CFR 20 implementation, JO CFR 50.59 issues, long term technical issues), source term reduction, ALARA planning and training.

The

Radiation Protection Manager {RPM) will no longer have direct line supervisory responsibilities; the Manager will, however, serve as an in-house assessor and report to corporate headquarters as well as plant management.*.

The inspector noted that the licensee will benefit in several ways -from th~ reorganization of the RSD.

Unlike the old organization all *..

operational phases of the RSD will fall within one _group, radiological services. Crafts will no longer be requir~d to contact several differ~nt groups within the RSD to get a job scheduled, an ALARA re~iew, a RWP generated or radiological services technical support. All of these tasks can be accomplished within radiological services.

Communication between groups in radiological services should also improve.

In addition, as a result of the reorganization many individuals within the RSD were given new job assignments which should *

enhance th~ expertise of individu~ls involved and aide in their.ta~eer development.

Another indirect ~enefit to the licensee will be the *.

technical review of many of the licensee's administrative and health*

• physi~s procedures.

During interviews, several new supe~visors.

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indicated that they were rewriting many of their procedures because they were outdated, poorly written and not routinely updated.

Th( ins~ector noted that procedures are not required to be reviewed technic~lly as a part of the licensee's biannual review process, quality* assurance {QA)

does not technically ~eview procedures, and only when a proceduie is

. revised is it required to be reviewed for technical competency.

The HP-self-assessment project in. 1990 concluded that although the contents of procedures were improving they did not provide the level of quality

• needed to efficiently control radiological activities. Again, the reorganization should help alleviate this problem. * Several new supervisors indicated that they did not have a detailed written job*

• description and were unclear about their specific responsibilities. The licensee recognizes this weakness and is currently updating the job descri pt i ans.

• A toncern was raised about the role of the RPM within the new organization. Administrative Procedure No. 7.00 stipulates that the*

Radiological Services Manager {RSM) or Radiation Protection Manager {RPM as defined in Regulatory Guide {RG) 1.8) shall be the Health Physics Superintendent {HPS) and have numerous responsibilities within the HP program inc 1 ud i ng the admi n i strati on of the respiratory protection

• • . / *

program, oversight of the HP instrument calibration program, approving work permits and evaluating HP activities. Under the new organization, the HPS title was changed to the Superintendent of Radiological Services

{SRS); a ne~ position, RPM, was created; many of the responsibilities of.

the HPS were given to the SRS; and the RPM would no longer have supervisory responsibilities within RS but would instead assess the.RS

• program and report directly to both RS management and corporate headquarters. Although the new administrative procedures detailing the*

specific responsibilities of the SRS and the RPM were in ~evision and unavailable.for review; the inspector did discuss with' the licensee the need for ensuring that whoever assumed the responsibilities of the RPM, not just the.title, would conform to th~ requirements ~f RG 1.8. The.

licensee agreed to r~view the regulatory requirements.

The *RSD staff has remained stable since the last inspection.- the.

licensee did not plan~to add additional staff until the next*refuel outage scheduled for May 1993.

• No violations or deviations. were identified.

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5.

• Audits, *Surveillances and Self-Assessments. (Ip 83750)

Since the last inspettion, the Quality Assurance (QA} program had undergone a reorganization..QA was renamed the Nuclear Performance Assessment Department (NPAD} and has a Di rector, a six member steer fog *

com~ittee, seven performance specialists and two functional groups; administrative and techni~al. Reporting to the committee will be seven perfor~ance specialists; each responsible for one of the seven functional areas of Systematic Assessment -0f Licerisee Perfor~ance (SALP}, and the two.functional~group supervisbrs~ *The assesso~s; including those for Big Rock Point, were pooled into the technical group and will be shared by both plants. The assessors will continue to

.

perform the mandatory QA audits and surveillanc*e~.

In addition,. NPAD will perform assessments -0n departmen~s ~t both facilities~ report their findings to plant management, and work closely with management to ensure that correct*i ve actions are taken for reported defi ci enci es. These additional responsibilities raise concerns about whether ~r not*

assess6rs ~an work. that clos~ly, on a day to day basis, with any department or group ahd still maintain their objectivity while performing audits and surveillances. *This concern wa~ raised with the Assessment Program Supervi~or and discussed at the ~xit meeting.

The inspector revi~wed Quality Assurance ~urve~llances conducted since.

• the last inspection: nine Deviation Reports (DR}, 21 Radiological Deficiency Reports (RDR}. and.four.:Radiologi.cal Incident. Reports (RIR}.

Surveillance Report S-AP-92-029 was conducted to asses~_the effectiveness of the radiological work practices and adequacy of radiation safety job cov~rage during the 1992 Refueling Outage.

The *

surveillance reported that some workers not actively involved in all of the job steps were found to be present at job sites, workers in full.

protective clothing and respirators had to climb numercius long ladders to get to a job site, one High Radi~tion Area ~ign did not accurately reflect the actual ccinditions present, vacuum cleaners with high

.radiation dose rates were found in corridors and some postings needed updating.

The surveillance ~eported that, in all cases, the identified problems were immediately corrected.

The inspector noted, however, that*

6.

• none of the observations resulted in the issuance bf a DR, RDR or RIR nor were long term corrective actions to preclude recurrence addressed.

The inspector reviewed the nine DRs written since June 1, 1992, and found that only one identified a deficiency in-the way radiation safety was conducting its program.

Four DRs were written on one* hot particle incident; two were written to de~~ribe difficulties in assessing the.

• airborne properties in the south tilt pit; and.two req~ested that RSD evaluate the mixed waste program and the need for including chemical hazards on radiation work permits.

The only *oR written to address a deficiency, was written for failing to perform an adequate -IOCFRS0.59.

evaluation of the interim radioactive waste facilities.

DRs appear to be used more for requesting evaluation.s or des.cribing activities than for reporting deficienci~s. This conce~n ~as raised at the exit.

meeting.

• The inspector reviewed the 21 RDRs and four ~IRs written since~

January 1, 1992, and noted the following:

RIRs will no longer be used

• to report deficiencies; the licensee needs to clearly define what

"dedicated" and "zone" RS coverage means and when it is needed; the *

l~censee needs to clearly deffrie what Rcontrol" of high radiation areas

.

mean; RDRs written for personal contamination events should include the.

act~vity of the contamination; corrective actions were ineffecti~e, _in *

some cases, in precluding recurrence of similar events;.and recommend~d

. cbrrectiv~ actions were not being incorporated into protedures,.

• . :

. practices, guides or instructions*. * for *example, several RDRs reported deficiencie~ in the RS technician cbverage of high risk jobs where.**

ambient dose rates were close to but did not exceed 1 R/hr.

The recommended corrective action in the RDRs called for "dedicated" RS technici~n coverage for ~hos~ and similar jobs.

By procedure, the duty HP is given the discretfon to decide when "dedicated" or some-other coverage (zone, intermittent) is needed for jobs *here dose rates are less th~n 1 R/hr.

To implement the recommended corrective action:the Duty HPs were.instructed to provide "dedicated" coverage for jobs similar to ones reported i.n the RDRs4 The corrective action, however, was not documented or incorporated into a procedure, practice or*

instruction.

By not documenting corrective actions the licensee cannot ensure that similar events wi 11 not occur in the future.. This concern was discussed at the exit meeting.

No ~iolations or deviations were identified.

External Exposure Control CIP 83750)

• During a review of the RDRs the inspector noted two incidents where RS technicians had lost control of high radiation areas.. By procedure, *RS.

technicians are required to unlock doors to high radiation ar~a~ for *

workers needing access and maintain control of the door until the workers exit the area.

In one incident, the RS technician unlocked the door to the reactor cavity, let two auxilia~y operators enter the area,

. telbcked the door and left. The operators discovered that they had been *

locked into the area when they attempted to leave.

In another e~amplei

a RS technician abandoned the 602' pipeway area even though the technician was responsible for controlling the high radiation door to the area.

In both cases the technicians were unclear about what

"maintain control" meant.

Corrective action for both incidents involved counselihg the technicians on their responsibilities f6r controlling high radiation doors and discussing the incidents at shift turnover technician briefings. Again, corrective action to preclude recurrence.

w~s not docu~ented. If the techriicians were unclear about what

"maintain control" meant this should have been.cla~ified in the procedure.

During the review of the Deviation Reports :the inspector noted four *

written to address one hot particle event.

Upon exiting containment, a worker was found to have a 100,000 cpm hot parti~ulate on his neck. Jhe particle.was removed and the worker released~ The particle was analyied and*found to contain approximately 6.43 uci Cr-Sl, 0.814. uci Mn-S4, l.6S uci Co-:S8, 0.303 uci Fe-S9 and. I.SS uci Co-60. *The licensee used several different methods (PAL and Varskin)* to.calculate and retard a total gamma and beta skin dose equivalent dose of approximately 7 Rem for the exposure.

The particle was later sent to another lab and under electron microscopy was found to contain trace amounts of zirconium not found in any of the licensee's components.

The licensee suspects that the particle* may have been brought into the plant from another facility and have sent the particle to another lab for further analysis. This in~ident demonstrates a definite improve~ent fn the licensee's.hot particle dose assessment program.*

• *

The inspectbr reviewed the licensee's use of electronic dosimeters after reviewing RDR 92-00S.. In February 1992, two workers entered. containment to hang shielding in the Rege~e~ative Heat Ex~hanger area of containment.

The dose r~tes in the area were from 800 to 1000 mRem/hr.

The workers were given alarming electronic dosimeters and assi~ned zone RS techniciin coverage; Due to high rioise level in ~he area, the.

• *

workers were unaware that their dbsimeters were alarming until the technician signaled them to check their dose. The workers immediately.

evacuated the area.

The* l icensee'.s procedures for responding to alarmihg dosimeters are precise; if on~ alarms the workers are instructed to. leave the area immediately and contact RS.

Recommended corrective action$ for this incident included assigning "dedicated" RS technician coverage to this job in the future and clarifying the difference between "dedicated" and "zone" coverage. Again, these corrective actions were not documented.

No violations or deviations were identified.

7.

Maintaining Occupational Exposure~ ALARA CIP 837SOl 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

progtam; establishment of goals and objectives, and effectiveness in meeting them.

Also reviewed were management techniques, program

• .experience and. correttion of self identified prog~am weaknesses.

Under the reorganization ALARA was split into two separate groups.

One group, operational,. became a part of Radiological Services and.the other, programs, became a part of Health Physics Technical.

~he operational group will continue to provide day to day ALARA support and the programs group will be responsible for long term projects including the source term reduction, the hot spot reduction program and engineering design changes.

Bringing operational ALARA into radiological services should improve the efficiency of both groups.

The licensee has a very good operational ALARA program.

The group and the planners meet regularly and have developed a good working relationship. Through training and experience, the planners have begtin to incorporate ALARA principles directly into job planning.. The health physics scheduler meets regularly with ALARA and the crafts and has the authority to." de 1 ay or ha 1t work that had not been reviewed or put. on the.

schedule.

Information about jobs appears to flow smoothly between groups and the RSD is usually aware of new jobs before they are placed *

on the daily schedule.

• lhe new ALARA programs group wi 11 be respons*i bl e for ALARA goals, the source term reduction program, the hot spot reduction program and * *.

engineering design changes.

The ALARA Program Coordinator will be **.

responsible for *ach of the programs and report the progress of each through his supervisor to plant management.

For example, the

coordinator ts responsibl~ for coordinating the efforts of all of the groups i~volved in source term reductipn and tci make sure that each group understands their responsibilities and can meet deadline~..

established by management.

Each source term objective and long term ALARA project is assigned an *Action Nuniber, assigned to a responsible in.dividual and given a completion date.

If.the date for completion is exceeded the responsible individual's manager is notified~ Due to the reorganization the RSD program was in transition duting.the irispettion and some of the r~sponsibilities had yet to be. assigned.

Progress in implementation of the program will be tracked in future inspections~

A real strength in the ALARA program is its approach to advanced training. Three courses are offered to enhance employees knowledge of ALARA printiples and to increase their radiation protection skills in high radiation areas, high contamination areas and high airbo~ne

.

contamination areas... The courses include ALARA training for engineers, the Supervisory ALARA Expectations Course and Advanced Radiation Worker training for everyone who works in the radiologiCal controlled area

{RCA). *The Supervisory ALARA Course teaches supervisors to recognize*

their responsibilities with regards to ALARA principles. *Advanced

.

Radiation Worker training is performance based; it puts workers through the ALARA review process and places them in simulation where conditions are similar to those found in high radiation, contamiQation and airborne

areas.

The Supervisory ALARA Expectation and Advanced Radiation Worker course~ began in the fall of 19~1.

If the total dose for emergent work during refueling outage REFOUT 92 is factored into the total dose for the outage, the licensee was very close to meeting th~ir dose go*ls.

The* licensee projected a total dose of 207 man-Rem for the outage and the actual total dose was 269 ~an-Rem.

Emergent work accounted for approximately 60 man-Rem.

In addition, the outage ~as extended for 15 days beyond its sch~duled completion date.

• Personal contamiriation events for the year were higher than projetted

{goal of 99 and actual of 118 through April 1992). During the inspection, the licensee indicated that their goal for total ~tation dose was 50 mRem per day, ~veraged over the year, and they fully expect to meet that goal in 1992.

• No violations or deviations were i d_ent i fi ed.

8.

Solid Radioactive Waste (IP 86750)

The inspectors reviewed the licensee's solid radioactive waste management program, including: changes to equipment and procedures, processing and control of solid wastes~ adequacy of required rec~rds, reports and notifications~*

.

.

.

The inspector reviewed the modifications made to the ~outh interi~.

radioactive waste storage facility, the north radioactiv~ material~.

storage building and the ~ast radioactive waste processing facility~**

The licensee has installed radiation.area monitors, continuous air monitors and fire detectors in the south and east buildings and had th~

alarms wired via the telephone lines to the ~ohtrol room.

In addition)

the buildings are monitored monthly for surface contamination and ambient dose rates. If the monitors or phone lines fail the buildings are monitored daily.

In addition, a portable high efficiency

.

particulate air {HEPA) system has been inst~lled in the ea~t processing building.

The inspector noted that the area monitors may have been placed iri the wrong locations td detect an accident {spill or crushed container)* and discussed the issue with the licensee.

.

.

.

During a tour of the east radioactive waste processing building and the surrounding grounds the inspector found a contaminated anti-tip frame

and its support plates stored adjacent to the building. Contamination -

levels were low, slightly above background, and the frame as ~ell as the bu i1 ding were surrounded by a fence with access through. a 1 o.cked gate.

Both had been boxed and covered in plastic both internally within the box and covering the box.

The inspector noted that the plastic covering on both containers was torn and the wooden containers ~ere water stained. The inspector was told that containers ~ere riot routinely s~rveyed and soil samples beneath and surrounding the containers had not

• been collected. *The inspector expressed concern over the fact that there app~ared to be no mechanism where followup surveys or soil samples would be taken in cases such as this to ensure contamination wasn't getting into the soil. The licensee indicated they have been reluctant

to.move the frame unnecessarily because of safety concerns due to its large size {it's about 16 feet high).

They are currently looking into disposal of these items. *

No violations or deviatirins were identified.

9.

Transportation of Radioactive Materials and Radwaste CIP 83750. 86750}

The.inspectors reviewed the licensee's transportation of radioactive material*s program, including: adequacy and implementation of written prbcedures, radioactive materials and radwaste shipments for compliance with NRC and-DOT regulations and the licensee's quality assurance program, review *Of transportation incidents involving licensee shipments

{if any}, adequacy of required records, reports, shipment documents and notifications and experience concerning identificatiori and correction of programmati~ we~knesses. *

The li~ensee made approximately 75 radioactive materials shipments, including radioactive waste sent for prricessing, since January rif 1992.

With only one exception {lnspectioh Report 50-255/92008{DRSS)) none ~f the shipments have restilted in a ~iolation of NRC or DOT re~ulations:

Although this is a good program there is one area Qf concern that mtist be resolved if the progra~ is to improve and that ~rea is the ad~quacy.

• of their procedures.

The procedures were not vritten to instruct a,.*

worker on the process for making a radioactive materials shipment~ The instructions are vague and unclear ab.out the regulatory requirem_ent's.

The licens.ee is aware of ihi s problem and is committed to revising the.

• procedures.

In April 1992 the licensee.made three radioactive waste shipments to SEG:

for compaction and incineration {approximately 25,000 cubic fe~t). Some of the waste was incinerated and the rest was compacted along ~ith the incinerator ash:

Some of that waste was shipped back to the licensee on April 30, 1992.

The li~ensee is aware that th~re has been some discussion about whether or not they are licensed to receive the processed waste.

They have decided to delay receiving any remaini~g p~ocessed waste from SEG. until a new rule addressing this issue has b~en issued by_ the NRC.

This proposed rule was published in the April 29, 1992 Fed.eral -Register, and allows reactor licensees to receive back byproduct and special nuclear material that has been sent offsite to b*e reduced in volume by compaction or incineration!

No violati6ns or deviati6ns were identified:

10.

Plant Tours CIP 83750. 86750)

The inspector toured the.rad waste buildings {section 9), the auxilia~y building and the turbine buildings. Housekeeping in the auxiliary and*

turbine buildings was generally very good.

Housekeeping in the turbine building needs improvement.

The inspector found numerous spider weds and some debris during the tours.

In the auxiliary building the

inspector found:

hoses draining contaminat~d liquids that had nrit been

y inserted into floor drains and liquid was dripping on the drain, a clean hose extending into a contaminated area, several inadequate survey maps *

and a bag of overflow* 1 aundry; None of these observat i ans were

considered significant and each was corrected immediately.

No violation~ or deviations were identified..

11.

Exit Interview CIP 30703)

The inspectors met with licensee representatives (deno~ed in Section 1)

at the conclusion of the inspection on July 10, 1992, to discuss the scope and findings of the inspection.

• During the exit meeting, the inspector discussed the likely infor~ational content ~f the inspection report with regard to documents or processes reviewed by the inspector during the inspection.. Licensee representatives did not identify any such documents or process as proprietary.. The following items were specifically discussed with the*.

licensee.

a.

Weaknesses in the licensee's prricedural review process.

• (Section 5)

b.

The failure to docu~ent corrective actions; (Sections 5 and 6)

c.

Questions about the new RPM's responsibilities.. (Section 4)***

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