IR 05000255/1992025

Forwards Safety Insp Rept 50-255/92-25 on 921019-23.No Violations Noted

ML18058B220
Person / Time
Site:	Palisades
Issue date:	11/13/1992
From:	Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML18058B221	List: IR 05000255/1992025
References
NUDOCS 9211230149
Download: ML18058B220 (10)

Text

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Docket-No.. 50~255 Consumers Power Company ATTN:

Gerald General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert; MI 49043

Dear Mr. Slade:

NOV 13.1992

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Subject:.

Routine Radiition Protection Inspection Condurited at the Palisades Nuclear-Plant on October 19~23, 1992

- This refers to the routine safety inspection conducted by Mr. D. W. Nelson of

• _ thi~ office on October l9-23, 1992, of activiti~s at the Palisades Nuclear Plant, authorized by NRC Operating License No.

DPR~20 and to th~ discOssion of our findings with members of your staff at the conclusion of the inspection.

The enclosed_ copy of our-inspection report i dent i fies areas examined* during.

the inspection~ Withiri these areas, the inspection consisted of a selective

• exam*i nation of procedures and represeritat i ve records~- observations, and

• interviews with personnel.

• No violations of NRC requirements ~ere_ identified during the course of this inspection.

Iri accordance* with 10 CFR 2.i90 o.f the Commission's regulations, a. copy of this letter and the enclos~d inspe6tion report will-be pJaced in the NRC.

- Public.Document Room.

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

Inspection Report

No, 50-255/92025(DRSS)

See Attached Distribution:

Sincerely,

William Sriell, Chief

Radiological Controls Section 2

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• Distribution:

REGION I I I

Report No.

50~255/92025(DRSS).

Docket No. 50-255

Licensee:

Consumers Power Company

• 212 ~est Michigan Avenue

• Jackson,.MI

49201 *

Facility N~me: Palisades Nuclear Plant

Inspection At:

Palisades S~te, Covert, Michigan

Inspection Conducted~ October 19-23~ 1992

Inspector:

.Approved By:

D. W. Nelson

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Radiation Specialist*

William Snell, *Chief

Radi~logical Controls Settion 2

Inspection Summary

Lf~ense No. DPR-20.

Date*'

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Inspection on October 19-23. 1992 <Report ~o. 50-255/92025CDRSS))

Areas*Instiectid:

Routine unanno~nced inspection of the radiation protection,'

environmental and effluent monitoring ~r6grams~ including: * organization,

management controls and training~ audits and surveillances~ gaieous and liquid

radioactive wast~; solid radioactive.waste storage; effluent *and environmental.

reports;.proces~ monitor control and calibration; and mete~rologital

instrumentation operability (IP !6750, 84750).

Results:

No _violations or deviations were identified. The licensee's

environmenta.l and effluent monitoring programs appear :to be effective.. in

accomplishing th~ir assigned tasks. Strengths include the review and revision

of the environmental and effluent monitoring procedures~ the. continued good

fuel performance as demonstrated bythe very low level of radioactivity in

their effluents, and housekeeping in the auxiliary and radioactive waste.

buildings. Areas where improvement appears to be ni~r.ited is training (beyond

the in~house radiation protectiori (RP) core curriculum) given the new

• supervisors of the environmental and effluent programs, and documentation of

follow-up of "deficiencies" found during Nuclear Performance Assessment

• .Department (NPAD) audits and surveillantes.

9211230159 921113

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DETAILS

Persons Contacted

• • D. Anderson, Nuclear Performance Assessment

• P. Donnelly, Safety and Licensing Director

• • J. Kuemin~ * L.ice.rsing Administrator

• M. Mennucci, Health Physics {HP) Technical Supervisor

• T. Neal, HP Support Superintendent

• • R. Rice, Nuclear Performance Assessment

• G. Slade, Plant General Manager

• J. Stuedeman, Duty HP Supervisor

• G. Sturm, Radioactive Materi~ls Control Supervisor

• D. Passehl, Resident Inspector

_The inspectors also interviewed.other licensee and contractor personnel

during the course of the inspection.

• Denotes those present at the exit ~eeting on October 23, 1992.

General

• This in*spection was conducted to review aspects of the licensee's

. radiation protection, environmental *and effluent monitoring programs.

The inspection included tours of radiation controlled areas in the *

auxiliary and radioactive waste buildings, a tour of the environmental*

sampling ~ites, observations of licensee activities, revfew of

representatfve records and discussions with licensee personnel~

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Organization and Management Control~ CIP 83750. 84750)

The inspector reviewed the licensee's organization and managem~nt

controls for the environmental and effluent monitoring programs

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including: *organizational structure, ~taffing, delineation of authbrity

and management techniques used to implement the program and experience

concerning self-identificatiori *and correcti.on of program implementation

weaknesses.

.On June 30, 1992, the Radiological Services Department {RSD) reorganized

and, as a result, two individuals were reas~ighed to supervise the

environmental and effluent monitoring programs.

E~en though both

individuals had extensive radiation protection experience neither was

initially qualified by training or experience to assume responsibility.

for their programs.

Turnover time in their respective departments

{programs) was minimal and neither individual was sent off-site for

additional preliminary training.. * Both did, however, recefve ba~ic in-

house training on the requirements of their programs and both were

continuing to receive on-the-job training. The.inspector noted that

neither program.had failed to meet any of the requirements due to the

lack of experience of the supervisors.

The concern about the lack of

training for new supervisors was raised at the exit meeting.

In the last inspettion report (Inspection Report 50~255/920iO(DRSS it was reported that following the RSD ieorganization the Radiation Protection Manager {RPM} would serve as an in-house assessor and ieport to corporate as well as plant management. That was inaccurate; the *RPM wil1 only report to plant management. Two other inaccuracies were:

radiological. services not ALARA will be responsible for the hot spot reduction program and HP technical not ALARA _will assume res pons i bil ity for engineering design changes. . Inspection Report 50-255/92020(DRSS) indicated that the l_i~ensee would. * benefit in a number of ways from the reorganization of the Radiological Services Department (RSD}. During the inspection, two of these benefits were already apparent. Many of the new managers had al ready begun to * review and revise their procedures. In the effluent program alone the new supervisor had reviewed and revised most if not all of his procedures. In addition, Administrative Procedure No. 7.00 had been revised to include detailed job desc~iptions for all RSD managers (managers, coordinators supervisors, superintendents and the Radiation . Protection Manager (RPM)).

Since the last inspection, the RPM left to a~sume another position. The RPM from the Big Rock Point Power Plant was chosen to replace him and will report for duty sometime around January 1, 1993. Following the reorganization the RPM lost some of the respo.nsibilities historically . ass9tiated with that position to the Radiological Services (RS} Superintendent. In Inspection Report *50-255/92020, a *question was

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ratsed abo~t whether or not the qualification guidelines of Regulatory Guide 1.8 apply to an individ~al who assumes many of the responsibilities of the RPM but not the title. The new RPM will be asked to examine this issue.

The licensee has notified the NRC that it will implement the provisions of Generic Letter 89-01 and remove the* Radiological Effluent Tech_ni cal Specifications (RETS) fiom the main body of the Technical Specifi~ations and place them in the Offsite Do~e.Calculation Manual. As a re~ult the Limiting Condition of Operation (LCO) will change to a "Control" format for ODCM entries.. The change will occur sometime in the winter of 1992~ 1993. No violations or deviations were identified~ 4. Surveillances and Self Assessments CIP 84750) The inspector revi~wed the results rif the annual NPAD audit conducied by

• the 1 i censee on the effluent and* en vi ronmenta 1 monitoring programs.

Also reviewed was the extent and thoroughness of the audit.

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. . The la~i audit of the effluentand environmental programs was conducted September 30 - October 4, 1991. The audit was to assess: Technical Specification (TS} effluerit monitor bperability and calibrations; the Offsite Do~e Calculation Manual {ODCM}; the Radiological Environmental Monitoring Pr6gram (REMP}; vari6us REMP/Radiological Effluent Technical Specifications (RETS) surveillances and reports; off-site environmental. . sample collection activities; operability of equipment; stack-gas filter changeout and follow-up of implemented corrective actions from the

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previous audit (1990). The audit identified four observations/ recommendations: a mix-up of data sheets, a minor math error in the . Semi-annual Radioactive Effluent Release Report, a problem with the hard copy retention of TS surveillances (they were retained on microfilm and the originals discarded) and a*stack gas recorder that was found.to be recording on the ~rang scale~ These wer~ considered to be of minor significance and no corrective action document (AC:tion Item Report (AIR) or Deviation Report (DR)) was issued.

Two other items discussed in the audit, however, raised questions about NPAD's criteria* for identifying, reporting and tracking "conditions adverse to quality" (concerns, deficiencies, ffndings or violations). One item identified the continuing problems-with air sample data results due to the.poor work prac;t ices utilized by their contractor. Even though this problem had been reported in a 1990 inspection report (50- 255/90022(DRSS)) and the REMP coordinator had taken acti-0n to coirect it (~ letter to the contractor), the pooi practices had continued: Jhe other item reported that se~eral process monito~s had been out of. serv~ce for extehded periods of time and the licensee's corrective actions ta.ken to fix the problem appeared to have* been inadequate. The inspector noted that.neither of these items had been re~o~ted as a condition adverse to qualitj and corrective action documents had not been writte~ to.~ddress them. Following *the audit, one of the NPAD auditors did call the *REMP coordinator on several occasions to see if ior~ection action~ had been.taken but had not documented the conversat iOns. The inspector a 1 so n.oted that NPAD had *not conducted a surveillance on either the effluent or environmental programs in the year following the audit and none had beeri scheduled for 1993. Th~*fact that NPAD ~as finding deficiencies in a program but riot adequately documenting and tracking them indicates a weakn~ss in the program. The insp~ctor discussed this issoe with the NPAD_and raised it at the exit meeting. No violations dr d~viations were i~entified. 5. Maintaining Occupational Exposure ALARA CIP 83750) Tot~l station dose for the first eight months of 1992 ~as 281 person-rem or 96% of.the revised target of 293 per~on-rem for the year. During August the average daily dose was 65 mRem/day. This was slightly higher than the daily dose for July and should this trend continue the total person~rem dose should be close to that predicted for the year. * The number of personnel contamination events. for the same* period was about -. - 139% of the 1992 plant ~oal of 99. A significaht amount of total outage*

• dose (59 person-rem out of a total of 269 person-rem) was due to

emergent work. This had an adverse effect on the projected dose for the outage as well as the year and may have had an impact on the number of PC Is.. Auxiliary Building contaminated footage increased from 12% in July to 13% during August. This continued a trend seen throughout the year -0f the total contaminated footage stayi~g just above the 1992 plant goal of 10%.

No violat,ons or deviations were identified.

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6. Meteorological Parameters (IP 84750) The inspector reviewed the meteorological tower data availability records for the first nine months ~f 1992. During that time the ~onthly pe~cent availability of each parameter indicated that w1th.one

• exception, all parameters were available 100% of the time.

The only exception occurr_ed in February and March 1992 when the, 60 meter wind speed indicator was down 5% of the time due to icing. Full calibratioh and maintenance services were performed in-March 1992 per requirements and all instruments were performing within tolerances.

.No violations or deviations w~re identified. 7.. -Gaseous Radioactive Wastes (IP 84750) The ihspector *reviewed the licensee's ga~eous radioac~ive waste manageme~t progra~, including: ch~nges in equipment arid procedures; gaseous* radioactive waste effluents for comp 1 i ance with regulatory . requirements; adequacy of r:equired records, reports, and notifications; ~rocess and effluent monitor~ for compliance with operational requirements.and experience con~erning identification of programmatic weaknesses.

The inspector reviewed the calibration records for a number of gaseous, process monitors including~ RIA-1113 {waste gas}, RIA-0631 (condenser offgas}, RIA-2325 (main st~am/dump valve} and RIA-2320 (steam generator blowdow~ vent). The calibrations appeared to meet the TS requirements for timeliness and tontent and the procedures used were comprehensive. and user friend*ly. In addition, the inspector noted that when a problem arose (questionable data points for example} the issue was discussed. with management arid the results of the discussion documented. The inspector reviewed an Instrument and Calibration Engineering (I&CE}

• report to manage~ent on the process radiation monito~s trending program

and.*noted that from 1988 through 1991 (four years} the average availability (percentage} for newer digital mo~itors was 9S.58% compared to 97.45% for the older analog monitors.* The report did not, however,. indicate whether numerous monitors were unavailable f6r short periods of time or a few monitors were unavailable for extended periods of time. The effluent group does not routinely track the performance of indiv1dual monitors during releases; operability records are kept by I&CE. The 3rd quarter I&CE process monitor report did indicate that the availability of monitors during releases had improved: Several monitor$ had been upgraded and the licensee was contemplating replacing others. Inoperable mon-itors. were reported per the requirements of both the Technical Specifications and the ODCM {Section 9).

The inspector reviewed selected.records of radioactive gaseous effluent releases including the Semiannual Radioactive Effluent Release Report for the first half of 1992. The samples collected and analyses performed appeared to comply with Technical Specifications. Total ga~eous effluents released during the first half of 1992 consisted of approximately 75.33, 7.201E-t, and 3.33 curies of hoble gas, radioiodine and tritium, respectively. Gaseous releases remained well below one percent of allo~able annual limits and indicated continuing good fuel

. " . . . performance. One incident involving an unplanned release occurred during the reporting period. On January 6, 1992, the escape airlock inner door equalizing valve stuck open for 35 minutes (LER 92-004-02) arid approximately l.34E-02 turies of contaminated air was released. This was noted in the Semiannu~l Radioactive Effluent Release Report. The inspector observed the collecti6n of weekly particulate and iodirie samples from the stack. The samples were collected using good RP * practices. *The samples were analyzed.and the results recorded per procedure and in a timely ~anner~

No vidlations or deviations were identified. 8. Liquid Radioactive Wastes CIP 84750) The inspector reviewed the licen~ee's liquid radioactive wa~te management program, including: liquid radioactive waste effluents for compliance with regulatory requirements; the adequacy of required r~cords, reports, and notifications; pr6cess and effluent monitors for compliance with operational requirements and experience concerning identification and correction of programmatic weaknes~es.

. . The inspector reviewed selected records of radioactive liquid effluent releases and the Semiannual Radioactive Effluent Release Report for the* first half of 1992. During that time there were 4 radioactive liquid .effluent batch releases consisting ~f 8.86E-05 liters and* 4.41E-03 curies total activity (excluding *tritium, gross alpha, and dissolved and* entrained gases). The rel~ases included approximately 4.36E-2 curies of* tritium. No problems we~e identified. . . . The inspector reviewed the calibration records of a number of the liq~id process l)lonitors includi.ng: RIA-:0833 (ser*vice wa:ter system* effluent)", RIA-1049 (liquid radioactive waste effluent) ~nd RIA-5211 (turbine * *. building sump effluent). The calibration records appea,r to be complete and ~ithin the requirements of the Technical Sp~cifications. A~ain, whenever a problem arose it was discussed with managemeht and documented.

• Planning and scheduling-is responsible for tracking the calibrafipn

requirements for those monitors described in the Technical Specifications (TS). *The effluent group gets a monthly ~omputer printout of the calibration record for each of the monitors and is. re.sponsi*ble for ensuring that they are calibrated per TS requirements.

• A review of the printout indicated that.all of the monitors had been

calibrated within TS time constraints. Ther~ was.a concern within the . group, however, that* the planriing ~nd scheduling group would no longer track the calibration records rince RETS requirements were incorpo~ated. into the OOCM. This issue was discussed at the exit meeting.

. . As was the ca~e with the gaseous monitors, the ~vailability of liqu{d monitors appears to be improving. For example, since October 1992, tests have indicated that none of the TS monitor high alarm, high voltage and check source setpoints had drifted. In addition, during the third quarter of 1992 only one monitor was out-of-service for an

.1 extended perio~ of time (RIA~5211: (turbine building sump)) and that ~onitor was under consideration for replacement.. * No vio.lations or deviations were identified. 9. Effluent Reports CIP 84750). The inspector reviewed radiological effluent analysis results and the monthly environmental monitoring reports to see if they.met the regulatory.requirements.. . . . The inspector rev{ewed the Semiannual Effluent Relea~e Report for the first half of 1992. The reporting requirements of the Technical

Specifications were met. The report noted one unplanned release (Section 7) and ohe change in the ODCM. In addition, they reported that

• they had found that two main steam 1 ine radiation elements (RE-2323. and

RE-2324) were not e~vironmentally qualified per 10 CFR 50.49*and had declared them inoperable. Th~ gaseou~ and liquid effluents, solid radioactive waste and the summary of the radiological impact on inariwere all reported per regulatory requirements. No problems were noted. The inspector reviewed the in~house monthly environmental reports. No problems o~ deviations from the requireme~ts were noted. . No violations or deviations were* identified. 10. Envirorimental Monitori~g CIP.84750) The inspector.visited most of the air particulate sample collecting and direct radiation (TLD) monitoring stations and several of the v~getable sample sites. All of the sites were in excellent condition and the air particulate samplers were in calibration. No problems were noted. . . . . -:During the la~t year the licensee ha~ ~bserved a marked impfo~~ment in the work practices of their environmental sample collecting contractor. As a result -0f the problems identified in the 1990 NRC ins~ection report the licensee began to monitor the activities of its contractor. Their contractor analyzes as well as tollects the environmental ~amples. Monthly surveillances (HP 10.1 and 10.10) are performed to ensure th~t radiological monitoring programs are substantially conducted as. described in the TS. Each surveillance includes: ~erification that. sample collection checklists.are completed and sighed; air sample volume . is checked at each site and the results recorded; calibration dates are

• chetked and verified against the master air meter calibration file; the

monthly analytical results are compared to the TS and Lower Level of Detection (LLD) requirements and devi~tions in the progr~m are submitted through the corrective action system. A review of the. surveillances indicated that many of the problems identified in the 1990 NRC * inspection report and the 1991 audit had been corrected. . No ~iol~tions or deviations were identified. 7.

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11;. Plant Tours (IP 83750. 86750) During a tour of the auxiliary and radioactive waste buildings the inspector noted the following: postings, labeling and radiological . controls in the radioactive waste and auxiliary. buildings were in . ac:c*ordance with regulatory and 1 i ~en see protedura 1 ;*equirements and. housekeeping in the readily accessible areas of the auxiliary and radioactive. buildings was very good to excellent. The inspector d1d find a plastic hose used to drain a contaminated valve spillipg liquid onto a floor (the hose was too short to reach the contaminat~d drain). This problem was fixed immediately and no other problems were observed. The inspector noted during the totir of the ~otith radioactive waste storage building that the ~rea radiation monitor had been ~oved tfr a location adjacent to the stored waste containers. The monitor.had been attached to the wall and may not have been-able to detect a spil~. The inspector also toured a contaminated material storage building. . located adjacent to the south radioactive waste storage building. The inspector noted that since the last in~pection all of the material in* *. the building (mostly scaffolding} had been placed in large metal boxes~ This is definitely an.improve~ent, the contaminated material had been stacked throughout the building and may have been a fire hazard. During a tour of the east radioattiv~ waste building the irispector noted

• that the anti-tip frame and its support plates had not been moved

(Inspection Report 50-255/92020(DRSS)). The inspector was shown an action plan developed by the radioactive waste group that commits the licensee to moving the frame and plates indoors as soon as possible. The licensee had been unable to move the object~ because the ground *

• surrounding* the frame had been wet during much of the summer and fall

and they were concerned about an accident occurring during the move. No violations or deviations were identified. . 12. Exit Interview (IP 83750. 84750, 86750) The inspector met with 1 i censee representatives (denoted in Section_ 1) at the conclusion of the inspection on Pctober 23, 1992, to discuss the scope _and finding~ of the inspection~ During the exit interview, the inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. Licensee representatiyes did not identify any such documents orprocesses as pfoprietary. The following items were specifically addressed at the exit meeting: a. The lack of training for supervisors (Section 3).. b. c. The tracking of process monitors (Section 8). Observations made during the tours (Section11). 8 }}