IR 05000255/1993009
| ML18058B859 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/26/1993 |
| From: | Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18058B860 | List: |
| References | |
| NUDOCS 9306070463 | |
| Download: ML18058B859 (12) | |
Text
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:
MAY 2 6 1993 SUBJECT:
ROUTINE RADIATION INSPECTION AT PALISADES NULCEAR PLANT This refers to the routine safety inspection conducted by Mr. D. W. Nelson of this office on April 26-29, May 6-8 and May 10-12, 1993, of activities at the Palisades Nuclear Generating Plant, authorized by NRC Operating License No. DPR-20 and to the discussion of our findings with members of your staff at the conclusion of the inspection.
- 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 and representative records, observations, and interviews with personnel.
No violations of NRC requirements were identified during the course of this inspection.
- In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will* be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Enclosure:
Inspection Report
No. 50-255/93009(DRSS)
See Attached Distribution
CJ40G5~
Sincerely,
Ori&inal Siined By Wiiliam Snell
William Snell, Chief
Radiological Controls Section 2
- Consumers Power Company
Distribution
REGION I I I
Report No. 50-255/93009(DRSS)
Docket No. 50-255
License No. DPR-20.
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted: April 26-29, May 6-8 and May 10-12, 1993
Inspector:
Approved By:
D. W. Nelson
J
Radiation Specialist
William Snell, Chief
Radiological Controls Section 2
Inspection Summary
Date'
'
Inspection on April 26-29. May 6-8 and May 10-12. 1993 (Report
No. 50-255/93009CDRSSll
Areas Inspected: Routine announced inspection of the radiation protection
program including: organization and management controls; external exposure
control; control of radioactive materials, contamination, and surveys;
maintaining occupational exposures ALARA (Inspection Procedures (IP) 83750);
refuel outage planning; and preparation and performance during the dry cask
storage project (IP 83750).
Open items from past identified concerns
(IP 83750) were also reviewed.
Results:
No violations or deviations were identified. The licensee's
radiation protection program appears to be effective in controlling
radiological work and in protecting the public health and safety. Strengths
included staff stability, the reorganization of the radiological services
department (RSD), the job scheduling and planning group and RSD planning for
the dry cask storage project. Areas where improvement appeared to be merited
included housekeeping practices in infrequently visited areas of the auxillary
building, radiation protection practices during the dry cask storage project
and radiological access control.
9306070466 930526
ADOCK 05000255
O
- DETAILS
1.
Persons Contacted
- J. Beer, Radiation Protection Manager
- A. Clark, ALARA Program Coordinator
- K. Haas, Radiological Services Department Manager
- * C. Hillman, Licensing
- J. Kuemin, Licensing Administrator
- D. Malone, Radiological Services Superintendent
- M. Mennucci, Health Physics (HP) Technical Supervisor
- T. Neal, HP Support Superintendent
- R. Rogers, Safety and Licensing Director
The inspectors also interviewed other licensee and contractor personnel
during the course of the inspection.
- Denotes those present at the formal exit meeting on April 29, 1993.
- Denotes individuals present at informal exit meetings held May 8 and
May 12, 1993.
2.
General
This inspection was conducted to review aspects of the licensee's
radiation protection program.
Included in this inspection was a
followup of outstanding items in the areas of radiation protection. The
inspection included a tour of radiation controlled areas in the
auxiliary building, containment and the spent fuel pool; observations of
licensee activities; review of representative records and discussions
with licensee personnel.
3.
Licensee Action on Previous Inspection Findings CIP 83750)
(Closed) Open Item 255/9i011-02: Untimely input of survey results into
radiation work permits (RWP).
The inspector reviewed the newly revised (April 6, 1993) Administrative
Procedure on Radiation Work Permits (RWP) and found that the issue of
timely input of survey results had been addressed in the procedure. The
procedure requires in part that RWPs be put on hold until confirmatory
surveys due to changes in radiological conditions are received, reviewed
and addressed in the RWP.
In addition, the RSD Planning and Scheduling
group were responsible for reviewing all work requests and assuring that
sufficient time was allocated to obtain the necessary surveys and
incorporate the results into a RWP.
This item is closed.
(Closed) Unresolved Item 255/91022-02:
The licensee's definition of a
restricted area appeared to be too all inclusive versus how it was
defined in 10 CFR Part 20.
I
This issue was brought back for management review and it was determined
that the licensee's definition of a restrictive area was acceptable.
However, to avoid future confusion, the licensee decided to modify the
definition.
The item remained open until the licensee had redefined
their restrictive area to only include those areas within the security
fence and the outlying radioactive waste buildings. All individuals
entering the restrictive areas would be trained, the extent of which
will be based on the likelihood of exposure from radioactive materials.
For example, escorted visitors will be given a handout addressing basic
health physics principles. All unescorted personnel, on the other hand,
will be required to attend General Employee Training (GET).
This item
is closed.
4.
Organization and Management Controls CIP 83750)
The inspectors reviewed the licensee's organization and management
controls for radiation protection program, including: organizational
structure, staffing, delineation of authority and management techniques
used to implement the program and experience concerning
self-identification and correction of program implementation weaknesses.
Staff stability continues to be a strength for the RSD.
Since the last
inspection (50-255/92025(0RSS)) the RSO has retained all of its
technical staff. One technician has given notice that he will be
leaving to join the staff at Big Rock Point prior to the scheduled June
4, 1993, Refuel Outage and the licensee had made plans to replace the
technician prior to the outage.
The inspector noted only one change in
the RSD at the management level; the former Radiation Protection Manager
(RPM) from Big Rock Point joined the staff in February 1993, as the
licensee's new RPM.
The new RPM wi 11 have no supervisory.
responsibilities but will instead perform assessments of the RSD for RSO
management and provide technical support to the staff when needed.
A
review of the new RPM's qualifications and responsibilities indicated
that the new RPM had met the requirements of Regulatory Guide 1.8. and
did have direct access to the plant manager.
No violations or deviations were iQentified.
5. *
RSO Radiation Protection Initiatives CIP 83750)
Since the last inspection the RSD has taken a number of initiatives to
improve the program.
a.
On January 1, 1993, the licensee implemented the new 10 CFR Part 20, one year prior to the mandatory starting date.
To implement,
the licensee spent approximately $255,000 for materials and
training and expended about 45 man-months of effort.
b.
The licensee installed a new large enclosed decontamination unit.
The unit allows the licensee to decontaminated large pieces of
equipment using the same abrasive materials. The unit should help
to reduce the licensee's radioactive waste costs.
- c.
The licensee began placing 26 electronic dosimeters (ED) at
various locations throughout the plant to track dose rates. If
the ED results closely mimic those of routine surveys the licensee
plans to reduce the number of surveys performed to save dose.
d.
The licensee continues to practice early boration and hydrogen
peroxide addition during shutdowns.
Early results from the April
28, 1993, forced outage indicated that early boration had reduced
the licensee's Co-60 inventory by approximately.1500 Curies.
e.
The licensee reduced the number of dosimeters issued to employees
by approximately 150. Dosimeters will no longer be issued to
clerical personnel and others who do not enter the RCA.
f.
The licensee purchased a number of new instruments including lapel
air samplers, Eberline AMS-4 continuous air monitors, a portable
germanium detector for source term characterizati*on and neutron *
dosimeters.
All of the above licensee initiatives are excellent program improvements
which are indicative of management's strong support of the RSD.
No violations or deviations were identified.
6.
Non-outage Planning and Scheduling (IP 83750)
Another direct benefit of the June 1992 RSD reorganization was the
formation of the RSD Health Physics Planning and Scheduling group.
(HPPS).
The licensee created the new group with members from the old
ALARA group.
The group has five members, these include the Health
Physics Planning and Scheduling Supervisor, the RWP/Planning Supervisor,
the HP Scheduler and two technicians. The group is responsible for
insuring that the RSD is aware of all upcoming jobs, coordinating job
planning with other departments, generating Radiation Work Permits and
short and long term ALARA planning.
Management support for the group
has been strong and as a result the RSD had gained greater control over
its own schedule.
In addition to gaining greater control over the schedule the
reorganization allowed the RSD to simplify its methodology for
processing of work order requests.
Essentially all non-emergent work
order requests must be processed through the group before the job is
authorized and a RWP issued.
Emergent work (non-routine work required
to keep the plant on line} can still be performed without the group's
prior authorization with the explicit approval of the Duty Health
Physicist. The process starts with the HP Scheduler. The scheduler
attends the 1300 maintenance scheduling meeting (the plant's primary
scheduling meeting) and reviews the Plant Daily Schedule to learn what
new work order requests have been added to the seven day schedule.
The
scheduler brings the information back to the group and the Planning
Supervisor determines if the work order has an associated authorizing
- package in the job history database. Greater than 99% of all jobs now
have an associated work package in the database.
The supervisor reviews
the package for radiation protection as well as ALARA concerns and
either authorizes the issuance of a RWP or requests additional
information from the work group's planner. After the review is complete
and the package authorized, the group generates a RWP based on
information provided by an old RWP and the survey data provided by
radiological services. All old RWPs are now in a database and new RWPs
-
are almost always cloned from the old ones. Again, the process
virtually assures that RSD is aware of all new work orders and can
allocate its resources accordingly.
Another enhancement started by the HPPS group was the "time-out"
meeting~ Following the 1300 scheduling meeting the scheduler downloads
the data from the daily planning schedule database {ARTEMIS) and loads
it into the group's database.
The data is rearranged and enhanced
{notes or comments added) and a new RSD schedule "Today's HP Office
Report" generated.
At the "time-out" meeting the scheduler meets with
the Duty HP to discuss those work orders requiring HP support during the
next three shifts. Technically, if a work order is not on the schedule
the Duty HP is not obligated to provide HP support until its put on the
schedule and the planning and scheduling group has reviewed the package.
The inspector attended one of the "time-out" meetings and reviewed one
of the "Today's HP Office Report" schedules and found both to be
comprehensive and informative.
At the meeting, the report was reviewed
and each work order discussed in some detail. The meetings have been so
successful that the RSD plans to increase the number of them during the
1993 refueling outage.
No violations or_deviations were identified.
7.
Outage Planning CIP 83750)
During the inspection the inspector reviewed the "Operations and Outage
Management - 1993 Refueling Outage" schedule, an item by item listing of
the work orders projected for the 1993 refueling outage scheduled to
begin June 4, 1993 and found it to be comprehensive but only marginally
useful for RSD planning purposes.
Some information was lacking in the
schedule so the HPPS group downloaded the master schedule into its own
database and generated a more useful document.
The new document lists
work orders by their respective room number and allows the group to
cross reference work orders in the job history database to the equipment
numbers of components in each room.
In addition, the group's staff had
been augmented with personnel from other RSD groups {four liaison
technicians and eight assistant duty HPs) who will assist with ALARA and
work package planning reviews and generating RWPs.
A review of the
progress made in reviewing the work orders indicated that while most had
been reviewed, progress in generating RWPs had been slow due to delays
brought on by the April 28 unplanned forced outage and preparation for
the dry cask storage project. Discussions with members of the group and
management indicated that the progress made by the RSD in reviewing the
work requests and generating RWPs for the 1993 outage had been much
improved over_that of previous outages.
No violations or deviations were identified.
8.
Maintaining Occupational Exposures ALARA CIP 83750)
The inspector reviewed the station dose for 1992 and found it to be
comparable with other similar PWRs.
Total station dose for 1992 was 295
person-rem compared to 182 person-rem for 1991.
Of that dose, 269
person-rem was accrued during the 72 day refueling outage.
When
compared with station dose from previous years (and ignoring the dose
accrued during the steam generator replacement project) the data
suggests a continuing downward trend.
The inspector further noted that
of the 295 person-rem for 1992, approximately 45 person-rem was accrued
during the Safety Related Piping Reverification Program (SRPRP), a
project indirectly related to the operation of the plant. A review of
the monthly dose reports for the first three months of 1993 indicated
the same downward trend.
However, on any given non-outage day SRPRP
work can double or triple that day's station dose.
Once the SRPRP
project is complete in 1996 the licensee expects to save, on average,
about 20 rem per year.
In addition, the licensee has set a target of
less than 50 days for the 1993 outage and if the target is met station
dose for 1993 should be well below the--1992 figure.
Station dose will
be closely monitored during the inspection planned for the 1993 outage.
Since the last inspection the licensee has allowed Instrumentation and
Calibration {IC) technicians to enter the 590' level of containment*
while at full power. Operators had been making weekly entries into the
590' level of containment to perform required technical specification
surveillances since the plant began operations, however, allowing entry
for routine work raised questions about whether or not this activity
violated ALARA principles. Prior to the first entry, the RSD made *
multiple entries into containment to characterize the gamma and neutron
dose distribution. The RSD used four different modalities to measure
the neutron energy distribution, the neutron flux and the dose rate.
These included metered three and nine inch Rem balls, Landauer NutrackER
multichip dosimeters, the licensee's Panasonic dosimeter with an 802
chip and several newly acquired neutron bubble dosimeters.
The survey
data indicated that on the 590' level of containment neutron as well as
gamma dose rates were less than 10 mrem/hr in those areas where the
instrument and calibration technicians would be working.
Following a
review of the data by the RSD HPs, entry into the 590' level was
permitted.
No violations or deviations were identified.
'i
,,
9.
Solid Radioactive Waste (IP 86750)
During a previous tour of the east radioactive waste processing building
and the surrounding grounds {Inspection Report 50-255/92022{DRSS, the inspector noted that the licensee had stored a contaminated anti-tip frame and its support plates adjacent to the building. The inspector further noted that the plastic sheeting covering both containers had torn and there was evidence that the wooden containers housing the. equipment had leaked. Subsequent to that inspection the licensee moved both pieces of equipment into the east radioactive waste building, collected and analyzed soil samples from under and adjacent to where the equipment was located and confirmed that the containers had leaked some contamination into the soil. Soil found to be contaminated was collected, placed in containers and stored in the east radioactive waste building. Other containers holding contaminated sand and soil from other sites were also moved into the building. The 1nspector reviewed the soil sample results from before and after the soil was removed and considered the matter closed. No violations or deviations were identified. 10. The Dry Cask Storage Project CIP 83750) During the first visit to the facility the inspector reviewed the licensee's preparation for the project and during subsequent visits observed the RSD's performance during the loading and transfer of the first cask. a. Planning. Overall, the RSD's preparation for the dry cask storage project was excellent. It was noted that the licensee had prepared a document cross referencing station procedures with the requirements of the cask's Certifi~ate of Compliance, had generated a detailed step by step procedure (FHS-M-32 "Loading and Placing the VSC into Storage") for loading and placing the cask in storage and had performed at least two complete dry runs of the loading and transfer of the cask prior to the start of the project. The inspector further noted that the RSD had inserted numerous radiological holdpoints into procedure FHS-M-32, had written a very detailed Work Instruction "Radiation Safety Monitoring Requirements For Dry Fuel Storage" in>.;rsupport of FHS-M- 32, had given their staff a significant amount of additional training in support of the project, and had generated six separate briefing packages and RWPs, one for each phase of the project. b. Moving the Multi-Assembly Sealed Basket (MSB} Transfer Cask (MTC} containing the MSB from the Spent Fuel Pool into the adjacent cask wash down pit and subsequent decontamination activities. The inspector observed the transfer of the MTC from the spent fuel to the cask wash down pit and noted the RSD technician's
preparation for the move. * In addition to the training received before the start of the project each technician had participated in at least one dry run of the transfer. The lead technician had held a job brief with the personnel involved to discuss the job specific RWP and.had visited the spent fuel pool on several occasions to insure all necessary equipment had been moved to the area. Even with the preparation, however, the inspector identified several concerns during the move. Although radiation protection coverage during the move was generally very good the inspector did observe several poor RP practices. The inspector observed a RP technician setting potentially contaminated equipment into an adjacent clean area; a worker remove his cloth bootie and step back into the contaminated area; a posted clean walkway adjacent to the spent fuel pool wet from spray from potentially contaminated water dripping from the hoist cables and spray from the T-90 rinse; and technicians spending too much time standing adjacent to the transfer cask - taking dose rate measurements. These concerns were discussed with RSD management immediately following the move. Total dose for the move was 54.7 mrem, much less than the 650 mrem projected. Dose rates on the exterior surfaces of the transfer cask were less than expected~ c. Welding and Non-Destructive Testing of the two MSB lids. Radiation protection coverage was not as extensive during this phase. The RP technician's responsibilities were limited to. monitoring workers doses, collecting air samples and contamination control. No problems were noted during this phase. Total dose for this phase was 514 mrem, again less than expected. Total dose would have been even lower if the welders had not had problems with the automatic welder. d. Transferring the MSB from the MTC into the Ventilated Concrete Cask {VCC)~ The RSD preparation and RP technician performance nuring this phase was very good to excellent. The. inspector did note, however, that RP technicians continued to spend a great deal of time standing adjacent to the MTC measuring dose rates. Although ambient dose rates surrounding the cask were generally in the low
- mrem range, standing adjacent to it for extended periods of time
is not a good ALARA practice. In addition, RP technicians continued to stand adjacent to the cask when dose rates increased half way through the transfer even though they had asked others present to move to lower dose rate areas. No other problems were noted.
- e.
Total dose for this phase was 120 mrem, again less than was expected. - Access Control. While observing the loading and transfer of the VCC the inspector noted several individuals entering the spent fuel area and leaving after only a short stay. The inspector noted that only one individual was asked to leave the spent fuel pool area during the MSB transfer into the wash down pit even though there were several individuals present watching the transfer. Technically only those individuals who had been briefed by the RSD technician and had reviewed and signed the RWP should have been in the area during critical stages of the project. Ultimately the Project Manager was responsible for insuring that only those individuals on the RWP were present. The inspector noted that the licensee had elected not to post a guard or an RP technician at the entrance of either the spent fuel pool area or the trackway even though there was some uncertainty about the potential dose rates during the transfer of the MTC from the pool into the pit and the transfer of MSB into the VCC. In addition, RWPs for other work in the spent fuel pool area had been issued prior to the project and were still active. Someone under another RWP and not involved in the project could have legally entered the area during one of the transfers and received unnecessary dose. Concerns about access control was discussed with RSD management and will be closely monitored during the next outage inspection. No violations or deviations were identified. 11. Plant Tours CIP 83750} During the inspection the inspector toured the auxiliary building and containment and made multiple visits to the spent fuel pool. Although the inspector found debris on the floor in three areas of the auxillary building and one area of containment, in general, housekeeping practices in both buildings was excellent. Postings, labeling and radiological controls in both buildings were found to be in accordance with regulatory as well as procedural requirements and all area surveys had been performed and the results posted in a timely manner. During the tour of east safeguards and the spent fuel pool the inspector noted that the licensee had elected to use yellow and magenta radiological floor tape to mark the boundaries of several small contaminated areas and had not used rope. Although this method for marking contamination boundaries is allowed by procedure it is generally not a good practice in areas where there is a lot of traffic. There was a lot of activity around the fuel pool on the day of the tour in preparation for the dry cask storage project and workers could have inadvertently stepped over the floor tape and entered the contaminated area. During subsequent visits to the spent fuel pool the inspector noted that ropes had been erected around the areas. In addition, the inspector found clean trash in many of the radioactive waste containers. The licensee has a policy
- '
restricting the amount of material brought into the RCA but has had difficulty controlling the amount of clean material placed in radioactive waste containers. The issues were discussed at the April 29 exiting meeting. No violations or deviations were identified. 12. Exit Interview CIP 30703) The inspectors met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on April 29 and May 12, 1993, to discuss the scope and findings of the inspection. During the exit meeting, 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 representatives did not identify any such documents or processes as proprietary. The following items were specifically discussed with th*e licensee. - a. Radiological practices during the dry cask storage project. (Section 10) b. Access control. (Section 10) c. Housekeeping practices in the auxillary building. (Section 11) 10 }}