IR 05000255/1997016
| ML18067A820 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/02/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18067A818 | List: |
| References | |
| 50-255-97-16, NUDOCS 9802100195 | |
| Download: ML18067A820 (26) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Docket No:
License No:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by 9802100195 980202
Consumers Energy Company Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 December 12-19, 1997 and January 14-16, 1998 R. L. Glinski, Radiation Specialist W. G. West, Radiation Specialist Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety
- EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/97016 This inspection was conducted to review the control room habitability system, the respiratory protection program, plant water quality, the plant chemistry program, fuel integrity monitoring, the post accident sample monitoring system, radiation worker practices, and ALARA post-job reviews. The following conclusions were reached:
Overall, the water quality for the primary and secondary systems was effectively controlled below industry guideline levels. Some primary coolant chemistry parameters did exceed recommended levels or listed procedural ranges, but the plant staff had established adequate technical reasons for these instances. Implemented and planned improvements indicated a strong commitment to excellent plant water quality (Section R1.1).
The licensee's fuel integrity group effectively monitored a wide variety of chemistry parameters to ascertain the fuel integrity. In particular, the staff concluded that the current data indicated the existence of one fuel defect, which is probably a large pinhole leak. The inspectors concluded that the fuel integrity group utilized appropriate methodology for this determination (Section R1.2).
Station staff conducted effective oversight of the respiratory protection program, as the surveillances and maintenance were satisfactorily completed as required. The equipment was in good working order and was cleaned and stored appropriately. Personnel using the equipment were properly trained, medically qualified, and properly fit-tested (Section R1.3).
One violation for the failure to post the high radiation area in the waste gas surge tank room was identified. Poor communications between the operations and Chemistry and Radiological Services (C&RS) departments was a significant contributing factor for this occurrence. In particular, the control room operators did not communicate sufficiently with C&RS regarding plant evolutions and the C&RS staff exhibited a narrow focus in their communications with operations staff (Section R1.4).
The make-up water system was well maintained and well managed, and the system effectively met plant needs for ultrapure water. The reliability and materiel condition of the various components were very good, as evidenced by the recent exceptional operating history (Section R2.1 ).
The licensee conducted effective oversight of the control room heating, ventilation, and air conditioning system maintenance and operation. The required surveiHances were satisfactorily completed and the various system components and equipment were in good working order (Section R2.2).
The training and inventories for the post accident sample monitoring (PASM) system were conducted in accordance with procedure. However, the performance of the PASM has been generally unreliable for the past two years, as evidenced by continued materiel condition, sampling, and analysis problems. In particular, unreliable hydrogen analysis and the lack of verification that PASM samples are representative of the reactor coolant are being considered an Inspection Followup Item (Section R2.3).
- The materiel condition and mechanical isolation performance of the accident high range monitors was very good, as evidenced by surveillance testing. However, the C&RS staff's failure to change out this filter resulted in greatly exceeding the shelf life of the iodine cartridge and the radiochemistry laboratory did not have a calibrated geometry to analyze this cartridge. Discrepancies in various documents indicated inattention to detai As the licensee may not have been able to sufficiently determine the iodine release in stack effluents under accident conditions, this issue is being considered an Unresolved Item (Section R2.4).
- Infrequent evolutions were generally well managed and expended reasonable radiation dose. However, the sludge solidification work exceeded the dose estimate partially due to the vendor's incorrect determination, based on cursory analyses, that sludge from the chemistry/laundry tank was compatible with the solidification process. The posting of the entrances into two large areas in the Auxiliary Building were inconsistent with NRC guidance (Section R4.1 ).
ALARA post-job reviews were well done and these reviews demonstrated that the staff was appropriately critical of licensee performance in a variety of areas. The reviewers identified several significant lessons learned which should enable the plant personnel to improve dose control for future outages (Section R4.2).
C&RS personnel have experienced communication problems with other station departments. The C&RS management was aware of these communication issues and indicated that there would be continued attention to improve the performance in this area (Sections R1.4, R4.1, R4.3, and R4.4).
Overall, the quality assurance and materiel condition of the laboratory and in-line instrumentation were very good, as evidenced by function checks and laboratory inter/intracomparison data. However, staff experienced communication problems regarding calibration of the gamma spectrometry system and infrequent problems with various chemical analyses (Section R7.1 ).
The Nuclear Performance Audit Department audit team was highly qualified, and the chemistry audit was extensive. This audit effectively identified areas for improvement and followed-up past issues to ensure proper resolution (Section R7.2).
- Report Details IV. Plant Support R1 Status of Radiological Protection and Chemistry (RP&C) Controls R 1.1 Control of Plant Water Quality Inspection Scope (IP 84750)
The inspectors reviewed the Final Safety Analysis Report (FSAR), the Technical Specifications (TS), chemistry operating procedures, and water quality data for the current fuel cycle. The inspectors also interviewed Chemical and Radiological Services (C&RS) staff regarding the control of various chemistry parameter Observations and Findings The inspectors noted that the normal ranges listed in plant procedures for various chemistry parameters for the primary coolant system (PCS) at power were generally 40%
of the guideline values listed by the Electric Power Research Institute (EPRI). The PCS data indicated that the fluoride, chloride, sulphate, and dissolved oxygen levels at power were generally well below the normal range limit of 20 parts per billion (ppb). The levels for these contaminants were also well below the FSAR and TS limits. As expected from the dissolved oxygen data, the PCS hydrogen level was generally maintained within the
. desired range. However, the inspectors noted a short period where the hydrogen level was slightly below the lower guideline value and the chemistry staff indicated that this was due to higher than normal helium levels in the volume control tank. The higher helium levels were due to the increased alpha radiation which resulted from higher levels of PCS boron and lithium (See below). This tank was subsequently purged and the normal PCS hydrogen level was re-establishe The inspectors also noted that the PCS conductivity levels for the first three months of the fuel cycle exceeded the guideline value listed in the operating procedure. Chemistry staff stated that the high conductivity level was due to the higher levels of boron and lithium required for reactivity control of the longer-lived fuel that was utilized for this fuel cycle. Since the C&RS staff believes that longer-lived fuel will be used in the future, they indicated that the normal range for PCS conductivity listed in the procedure would be reviewed. Although the elevated lithium levels (added for pH control) for the first three months of operation exceeded the 2.35 parts per million (ppm) listed in the current FSAR version as the upper limit for normal operations, the levels peaked at approximately 85%
of the administrative limit and the staff had initiated a FSAR change for the higher PCS lithium levels. The EPRI guidelines recommend a materials review for plants operating at elevated lithium levels for periods greater than three months and the insp.ector noted that a material review conducted by a qualified vendor in 1996 determined that this was appropriate as no chemistry related corrosion problems were identified.
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The inspector also noted that the PCS silica levels ranged from 1-1.5 ppm, which was higher than the EPRI guidelines and general practice within the industry. The licensee has an agreement with the fuel vendor to operate at this level of silica provided the sum of the aluminum, calcium, and magnesium levels in the PCS and other storage water is maintained below 100 ppb. Chemistry analyses for these cations demonstrated that the sum of their levels were consistently less than 10 ppb. Overall, the PCS water quality was well manage The normal values listed in the procedural guidelines for the steam generator (SG) levels at power for sodium, chloride, and sulfate were 20-30% of the EPRI Action Level value The actual levels at power were nearly always below the procedural normal values, with infrequent spikes of sodium and sulfate above 1 ppb and 3 ppb, respectively. The pH of the SGs was maintained between 8.5-9.5, boron was generally controlled between 8-10 ppm (to prevent SG tube denting), and silica was maintained below 100 ppb. The administrative limit for SG silica is 300 ppb to prevent carryover problems with the turbine blades. The iron and copper levels were maintained below 5 ppb and 1 ppb, respectively; indicating minimal corrosion product transport. The plant replaced the copper/nickel alloy condenser tubes in 1990 with stainless steel tubes, thereby removing the major source of secondary copper. Hydrazine was well controlled within the appropriate limits, and the feedwater and condensate dissolved oxygen levels were continuously below 1 ppb. All of these chemistry parameters were controlled at levels well below the EPRI guidelines, indicating excellent secondary system water qualit The inspectors also reviewed the secondary system mass balance determinations (MBD), which are generally done after plant shutdowns to determine the main sources of chemical contaminants. The March 1997 MBD indicated that the predominant source of chloride and sulfate in the secondary system was condenser in-leakage. The November 1997 MBD results were different. The chloride MBD was rather indeterminate, and the sulfate MBD indicated that a chemical addition tank (T-16) was the primary contaminant source. Chemistry staff stated that since there were no changes in condenser operation, the results indicated the possibility of higher contaminant levels in either the hydrazine or morpholine used in the secondary system. The inspector noted that the C&RS staff utilized a computer program which was de~eloped in accordance with the procedural equations to calculate the MBD and that staff are currently deriving MBD equations to more accurately represent the secondary system operatio The C&RS staff made some recent improvements in the water quality program and further actions are planned for implementation. The staff recently began to use a calculated pH for feedwater rather than a pH measured by the in-line instrumentation, as the measured pH was artificially low due to the high purity of the water. The calculated values have resulted in a lower addition rate for ammonia, which subsequently decreased the use of demineralizers. The licensee also modified SG blowdown demineralizer beds, which had been piped in parallel, to be piped in series. The two deminer(:!lizer beds in series now consist of a cation bed (which mainly removes ammonia) followed by a mixed bed. This improved the two week life of a single demineralzer to a six week life for the two beds in series. The cation bed is then disposed of as radwaste, but since the mixed bed contains only clean waste there is a significant reduction in radwaste generatio * The licensee had replaced 0.45 micron filters with 0.2 micron filters to reduce particulates, but the improvement was minimal. The staff has now planned to install filters with a pore size of 0.1 micron, as studies have shown that a large percentage of the crud particles are between 0.1-0.2 microns. The C&RS staff has also discussed the possibility of zinc injection into the primary system to reduce PCS dose rate Conclusions Overall, the water quality for the primary and secondary systems was generally controlled within FSAR, TS, procedural, and EPRI guideline levels. Some chemistry parameters of the PCS exceeded recommended levels or FSAR and procedural values, and C&RS staff established adequate technical bases for these occurrences. Several implemented and planned improvements indicate a strong commitment to excellent plant water qualit R1.2 Fuel Integrity Monitoring Inspection Scope (IP 84750)
The inspectors reviewed the PCS data for fuel integrity parameters, reviewed the most recent Fuel Integrity Report, and interviewed station staff regarding the fuel integrity monitoring progra Observations and Findings The licensee has assembled a team from the C&RS, reactor engineering, and operations departments to review PCS radiochemistry data for fuel defect indicators. This team reviews data on a regular basis and distributes a monthly Fuel Integrity Report to applicable staff members. Due to the dispersal of fuel pellets into the PCS in 1993, the PCS "background" for a number of fuel integrity parameters is high, and the staff genE}rally regard even incremental increases in PCS radioactivity as significant. Recent radiochemical analyses demonstrated that several fuel integrity parameters increased after the forced outage in October 1997, which included two separate reactor cool down Subsequent to this outage, the upward trend of the cesium-138, krypton isotopes, and dose equivalent iodine (DEi) concentrations increased, which is consistent with a perturbation of a fuel defect from the mechanical and thermal turbulence associated with reactor cool down activities. The staff also noted an increased level of xenon in the steam jet air ejector samples (generally indicative of increased primary to secondary leakage), which is consistent with increased levels of PCS noble gases from a fuel defec Due to valve problems, the PCS sample point prior to the forced outage was off the letdown, rather than the normal sample point from the hot leg. After the outage, the normal sampling point was used. Because the levels of cobalt-58/60 also increased after the outage, and since a peroxide treatment was performed during the outage, the staff considered that the increased PCS radioactivity may have been due to a combination of a typical outage crud burst and sample point differences. However, the most recent data indicated that the upward trend of neptunium-239, cesium isotopes, kryton isotopes, and iodines continued to increase. The DEi was currently at 5% of the TS limit of one
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- microcurie per milliliter, and extrapolation of the trend estimated that DEi would not exceed 6% of the TS limit prior to the upcoming refueling outage. Station staff indicated that the data was consistent with a large pinhole defec Conclusions The licensee's fuel integrity group effectively monitored a variety of chemistry parameters to ascertain the fuel integrity and the staff concluded that the data indicates at least one fuel defect, which is probably a large pinhole leak. The inspectors concluded that the fuel integrity group utilized an appropriate methodology for this determinatio R1.3 Respiratory Protection Program Inspection Scope (IP 84750)
The inspectors conducted a walkdown of the self-contained breathing apparatus (SCBA)
storage areas and the spare tank storage locations, and examined the materiel condition of the respirator facepieces and cartridges. The inspectors also reviewed the computer system used for tracking personnel respirator qualifications and issuance, the fit-testing program, and various maintenance and testing record Observations and Findings The inspectors noted that all required records were readily available, well-organized, and complete. The tracking system for SCBA tank servicing and inspection was very effective, as was the plant's computer tracking system for respirator qualifications. The inspectors did note that the lack of an automatic notification of unreturned equipment could lead to equipment tracking problems or unintended reuse. For example, there was a two-month old record that showed a respirator checked out to a visiting employee who was no longer at the plan The materiel condition of the respirator equipment was good. Cartridges and canisters were not being reused, and the equipment was thoroughly cleaned and properly store The licensee's respiratory protection procedures were detailed and met NUREG-0041 guidance. In particular, these procedures had properly incorporated recent changes in the medical qualification requirements of 10 CFR 20. The respirator fit-testing program was properly administered for all of the negative-pressure respirator types and for the powered air-purifying respirators. The licensee's training program for SCBA qualification was extensiv Conclusions The C&RS staff conducted effective oversight of the respiratory protection progra Required SCBA surveillances and maintenance were completed as required, the equipment was in good working order, and was cleaned and stored appropriatel Personnel using the equipment were properly trained, medically qualified, clean-shaven, and properly fit-tested.
- R1.4 Failure to Post a High Radiation Area Inspection Scope <IP 83750)
The inspectors reviewed the circumstances regarding the failure of C&RS staff to post a high radiation area in the waste gas surge tank (WGST, Tank T-67) room, which included radiation survey data and interviews with C&RS and operations personne Observations and Findings On January 7, 1998, at approximately 12:30 p.m., control room operations staff vented the volume control tank (VCT) to the WGST to*maintain the appropriate VCT pressure for optimal primary coolant pump seal performance. The presence of fresh PCS gas in the WGST significantly increased the dose rates in this room which was posted as a radiation area. Approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> later, two radwaste handlers entered the WGST room to conduct decontamination activities and one worker received an electronic dosimetry (ED)
alarm upon coming into contact with the WGS These workers exited the room and contacted C&RS staff. A health physics technician surveyed the room and determined that the general area dose rates ranged from 80-120 milliroegnten per hour (mR/h) and the contact WGST dose rates ranged from 150-200 mR/h. The radwaste handlers did not return to this room, as their radiation work permit did not allow entry into high radiation areas, and the analysis of the alarmed ED showed that the maximum dose rate measured was 102 mrem/h. Subsequently, C&RS staff posted the WGST room as a high radiation are CFR 20.1902(b) requires that the licensee post each high radiation area with a conspicuous sign bearing the radiation symbol and the words "CAUTION, HIGH RADIATION AREA" or "DANGER, HIGH RADIATION AREA". Pursuant to 10 CFR 20.1003 a high radiation area means an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 100 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates. Therefore, the failure to post the HRA in the WGST room was a violation of 10 CFR 20.1902(b) (VIO 50-255/97016-01 ).
The staff's response to the alarming ED was excellent, and much improved over previous occurrences (NRC Inspection Report 97015). However, the inspector expressed concern regarding the poor communications between the operations and C&RS departments, which was a significant contributing factor to this incident. In particular, the control room operators did not consider the ~ignificant radiological changes which could occur from this plant evolution. In addition, a number of discussions were held at the site regarding the increased VCT pressure and the need to vent the tank for optimal primary coolant pump seal performance, thus providing C&RS staff and management an opportunity to identify the potential for the increased radiation levels in the WGST room. The inspectors discussed with C&RS management that a broader and more proactive approach in their communications with other departments was needed to become aware of various planned plant evolutions which may change radiological conditions (See Section R4.3).
- Conclusions One violation for the failure to post a high radiation area in the WGST room was identified. The inspectors determined that poor communications between the operations and C&RS departments was a significant contributing factor for this occurrence. In particular, the control room operators did not communicate sufficiently with C&RS regarding plant evolutions and the C&RS staff did not sufficiently communicate with plant staff to determine whether plant evolutions could change radiological condition R2 Status of RP&C Facilities and Equipment R2.1 The Make-up Water System Inspection Scope (IP 84750)
The inspectors conducted a walkdown of the make-up water system and the associated in-line instrumentation located throughout the Feedwater Purity Building, reviewed make-up water quality data, and interviewed chemistry engineering staff regarding the operability and performance of the syste Observations and Findings The lake water used for producing make-up water was treated in the following manner:
(1) the water was treated with aluminum sulfate (alum) to precipitate a variety of chemical constituents, (2) the alum-treated water was filtered through a series of anthracite and carbon filter tanks to remove the precipitate and organics, (3) the filtrate was then passed through a green sand filter and a 5 micron cartridge filter in series to remove small particulates, (4) the water was chlorinated, '(5) passed through a reverse osmosis unit, and finally (6) the water was passed through a series of leased demineralizer beds which consisted of a cation/anion/mixed bed sequence. The chemical engineering staff indicated that the chlorination prior to reverse osmosis was done to treat the cellulose acetate membrane, as well as control the pH and sulfates. The make-up water was stored in the demineralized water storage tank (T-939). Analyses of T-939 water demonstrated that the system produced ultrapure water at a rate (100 gallons per minute)
to meet all of the plant needs, particularly plant start-up Discussions with plant staff revealed that the operability of this system was excellent, that the vendor for the leased beds was very supportive, and that the in-line instrumentation performed reliably. The inspectors noted that the materiel condition of the system was very good and there were no work order backlogs. During the October 1997 removal and replacement of the carbon granules in a filter tank, a vendor had mistakenly removed much of the support media as well, with the subsequent dispersal of carbon granules downstream of this tank to the 5 micron filter. The licensee's corrective action was to simplify this process by replacing both the carbon granules and support media for each tank every three years. The inspectors observed the installation of support media and carbon granules into a carbon filter tank and no problems were identified.
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/ Conclusions The make-up water system was well maintained and well managed, and the system effectively met plant needs for ultrapure water. The reliability and materiel condition of the various components were excellent, as evidenced by water quality data and the recent operating histor R2.2 The Control Room Ventilation System Inspection Scope (IP 84750)
The inspectors reviewed the control room heating, ventilation, and air conditioning (CRHVAC) system, which included a walkdown of the control room envelope, ducts, penetrations, and vestibules, as well as the air-handling units, emergency filtration trains, and associated dampers. In addition, the inspectors observed the applicable control room indicators, annunciators, and controls. The cognizant system engineering staff were interviewed and the applicable TS-required surveillance records were reviewe Observations and Findings The inspectors noted that all of the TS-required surveillances for particulate and iodine filtration and air pressure had been completed satisfactorily at the required frequencie However, one surveillance indicated that fresh air makeup to the CRHVAC system during emergency mode operation was 14% to 18% above the nominal design-basis value described in the FSAR, depending on which train was operating. The net effect of the increase in makeup flow was a slight increase in positive pressure in the control room envelope and a slight increase in resultant dose in the event of outside airborne contamination. A condition report was initiated as a result of this test result and the initial computer analysis of the increased flowrate indicated that a margin of safety still existed for the plant to meet dose limits prescribed in General Design Criterion 19; This analysis was still being reviewed by plant technical staff and an FSAR change request was in progress. The inspector reviewed the technical analysis of the increased flowrate and found it to be appropriat The inspectors found that all of the *cRHVAC equipment was in good working order. The emergency filtration units, air handling units, and fresh-air radiation detectors were well-maintained and functional. The only tagouts for these systems were in the control room and instructed operators not to manually close the fresh-air dampers, as the radiation detectors were downstream of them and these would not function properly when the dampers are closed. Currently, these detectors serve in an alarm capacity, with system switchover to emergency mode being a manual response to these alarm Plant man~gement stated that they had considered (and committed to) ar:i emergency mode auto-start function on an alarm from these fresh-air radiation detectors, but now
- believed that this was not necessary. This assessment was based on some preliminary technical analyses which considered the likely control room response time to these alarms, the alarm setpoints, the types of design-basis accidents necessitating auto-start,
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and the design of the CRHVAC system. The licensee is still reviewing the need to have these alarms auto-initiate the emergency ventilation system to meet the NUREG-0737 and General Design Criterion 19 requirement The CRHVAC system engineer was very knowledgeable of the system and he possessed a thorough understanding of the CRHVAC maintenance history, operation, and physical layou Conclusions The licensee conducted effective oversight of its CRHVAC system maintenance and operation. The TS-required surveillances were satisfactorily completed as required and the various system components and equipment were in good working orde R2.3 The Post Accident Sample Monitoring (PASM) System a:
Inspection Scope (IP 84750)
The inspectors conducted a walkdown of the PASM panel and interviewed C&RS staff regarding system operation. In addition, the inspectors reviewed various analytical results, maintenance activities, the.PASM logbook, PASM system he~lth assessments, and inventory and training record Observations and Findings The PASM training records demonstrated that each chemistry technician (CT) had operated the system and completed the analyses as required by procedure. The inventory records showed that the semi-annual equipment and supply checks were conducted as prescribed, and the CTs identified and corrected any deficiencie Although plant records indicated that the most recent inventory was completed, C&RS staff were unable to locate the checklists in the early portion of this inspection, which indicated a minor problem with document contro The licensee developed several procedures which described PASM operation and these appeared to be generally adequate for system training, sampling, and analysis. Plant staff conducted PASM activities in accordance with these procedures. The inspector observed that the overall materiel condition of the PASM panel was good. In addition, the PASM vendor has performed preventative maintenance (PM) on the panel in-line components on a semi-annual schedule and all the various PASM components were within the required calibratio However, the inspectors reviewed PASM records and determined that system performance was unreliable for much of the past two years due to a variety of problems, some of which were recurrent. These PASM problems (some of which have been resolved by maintenance and repair activities) included insufficient volume for liquid samples, valve and fitting leaks, valve failures, equipment deficiencies, and unsatisfactory results for the hydrogen concentration analyses of the liquid samples for much of 199 *
These failures to meet the hydrogen concentration acceptance criteria are significant, as the analysis of the PASM sample for hydrogen is utilized for determining the degree of fuel cladding damage. Consequently, the C&RS staff recently implemented a backup for this hydrogen analysis which involves laboratory gas chromatograph (GC) analysis of a PCS grab sample, in accordance with NUREG-0737. However, under accident conditions this backup method would result in a higher occupational dose. As the in-line GC will not be supported by the vendor through the end of the plant's life, C&RS staff planned to replace the GC with an in-line hydrogen monitor similar to that currently used for PCS hydrogen analysis. *
In addition to the above performance problems, the PASM was unavailable for 37 days in the third quarter of 1997 due to the failure of the containment heat tracing (which reduced the annual availability of the PASM to 85%) and the vendor PM identified a discrepancy between the installed and operating pressure for a pressure control valv The inspector identified a concern regarding PASM performance. The liquid sample that was routinely analyzed for chloride and boron content was an unknown prepared by the Laboratory Supervisor and not a sample obtained from the PASM. Although the laboratory results were always within the acceptance criteria, the licensee did not conduct any analyses of the PASM samples to ensure that the PASM is capable of delivering a representative sample of the PCS. The procedure utilized in support of NUREG-0737, El-15.3 - "Post Accident Sample Monitoring System Operator Training", described the PASM sampling and analysis, but the acceptance criteria for gamma spectroscopy consisted of a collected volume of 9-10 milliliters, rather than an actual laboratory analysis of the PASM sample to ensure representativenes Related to this, the licensee's PASM system assessment for the second quarter of 1996 stated that the practice of comparing PASM resuits to PCS grab samples was discontinued due to poor correlation of results, indicating that the staff had encountered problems verifying the representativeness of the PASM samples for some time. The inspector discussed with C&RS staff that NUREG-0737 states that PASM reactor coolant samples should be representative of the reactor coolant in the core area and that an analytical error of a factor of 2 was recommended. In response to these inquiries, the
. C&RS staff has planned to collect and analyze PASM liquid and gas samples in conjunction with the semi-annual vendor PMs to verify system performance as part of the Periodic Plant Activity Control (PPAC) program. Due to the continued problems with PASM hydrogen analysis and the lack of procedural guidance for PASM analytical tests to verify sample representativeness, the resolution of these issues will be tracked as an Inspection Followup Item (IFI 50-255/97016-02). Conclusions The training and inventories for the PASM system were conducted in accordance with procedure. However, the performance of the PASM has been generally unreliable for the past two years, as evidenced by various materiel condition, sampling, and analysis problems. In particular, the current program does not include any analysis to verify that
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the PASM sample is representative of the PCS and hydrogen analysis by the in-line GC has been unreliable. These PASM deficiencies will be reviewed in a future inspectio R2.4 The Stack Effluent Accident High Range Monitors Inspection Scope (IP 84750)
The inspectors walked down the accident high range monitors and reviewed the FSAR, the Offsite Dose Calculation Manual (ODCM), and the applicable procedures. Interviews with cognizant station personnel regarding the monitors operability were also conducte Observations and Findings The inspectors observed that the materiel condition of the accident high range monitors for stack effluents was very good and successful completion of the ODCM-required functional checks demonstrated that the mechanical isolations were acceptabl In response to the inspectors' questions regarding how often the accident high range iodine filter was changed out, C&RS staff determined that the current filter appeared to be the original cartridge from the 1983 installation. Further review by plant personnel found that the shelf-life for these silver zeolite filters was five years in a sealed plastic bag and that the vendor recommended a quarterly change out of these filters in the field. The inspector expressed concern that this filter was in the field well beyond the recommended shelf life. The staff has since procured several high range iodine cartridges and has scheduled a quarterly change out as part of its PPAC program. In addition, the staff has planned to send the original silver zeolite cartridge to an independent laboratory to determine the collection efficiency. In Table ll.F.1-2 of NUREG-0737, the listed adsorption efficiency for all forms of gaseous iodine is 90%. The high range noble gas detector was within calibratio The inspector also nsted that the radiochemistry laboratory did not have a calibrated geometry to analyze the accident high range iodine filter for iodine content by gamma spectrometry. The staff indicated that there was a specific spacer for counting the high range iodine filter, but this geometry has not been calibrated for several years. The C&RS personnel indicated that this geometry would be re-calibrated for gamma spectrometry analysis. Due to the iodine cartridge shelf life and gamma analysis issues, the licensee's ability to meet its commitments for iodine analysis of stack effluent under accident conditions was indeterminate. Therefore, this issue is being considered an Unresolved Item (URI 50-255/97016-03).
The inspector noted a slight discrepancy between the FSAR and the accident high range noble gas monitor procedure, as the FSAR states that this detector analyzes a 15-second.
grab sample and the procedure states that the sample is a 30-second sample. Plant personnel will time the sampling period during the next surveillance to determine which document is correct. The inspector also noted that the surveillance procedure contained a reference to an old TS requirement (TS 6.8.4) that has been transferred to the ODC These document discrepancies indicated a lack of attention to detail by C&RS staf * R4 Conclusion The materiel condition and mechanical isolation performance of the accident high range monitors was very good, as evidenced by surveillance testing. However, the C&RS staff's failure to change out the high range iodine filter resulted in greatly exceeding the shelf life of the iodine cartridge, and the radiochemistry laboratory did not have a calibrated geometry to analyze this cartridge. Documentation discrepancies indicated inattention to detail. As the licensee may not have been able to sufficiently determine the iodine release in stack effluents under accident conditions, this issue is being considered an Unresolved Ite Staff Knowledge and Performance in RP&C R4.1 Job Performance for lnfreguent Evolutions Inspection Scope <IP 83750)
The inspectors conducted walkdowns of the Auxiliary Building, attended work planning meetings and pre-job ALARA briefings, observed infrequent evolution activities, and reviewed occupational dose dat Observations and Findings The inspectors observed that the pre-job meetings for the sludge solidification (with the RVR-200 system) and the incore detector liner transfer jobs were well conducted. The pre-job briefings effectively reviewed the work sequence, expected radiological conditions, ALARA measures, job hold points, contingency/emergency actions, expected radiation monitor alarms, and the requirements for dosimetry and protective clothin Dedicated health physics coverage was provided for the applicable phases of these evolution The primary ALARA measure for the incore liner transfer involved transferring the incore probes from the storage cask to the shipping cask in the spent fuel pool to utilize the shielding of the water. The main source of occupational dose was expected from the decontamination, torquing, and radiological survey activities, as dose rates of 200 milliroentgens per hour (mR/h) at one foot from the shipping cask were projected. The dose estimate for this transfer was 300 millirem (mrem) and the actual dose was 273 mrem, which was reasonable for the work accomplished. In response to problems with attaching the crane hook to the shipping cask, the staff developed lessons learned including the use of a different hook and the possibility of transferring at a shallower depth for future transfers. The incore detectors were shipped offsite for disposa The primary ALARA measures for the sludge processing were the use of the conveyor room steel door as shielding for the drums containing the sludge and a camera for monitoring the drums remotely. The C&RS staff also conducted mock-up training for the sluicing activities to monitor the likelihood of splashing the radioactive sludge. The inspectors observed that the health physics coverage, radiological postings, and work
controls were well implemented. In particular, plant personnel stopped the work when the sluice wand became plugged with a cloth material. The staff sampled the sludges for 10 CFR 61 radwaste characterization when the drum contents were considered to be homogeneous. The original dose estimate for this job was 250 mrem and the planned work expended only 229 mrem. However, emergent work, repairs, and the failure of the chemistry/laundry sludge to solidify caused the staff to expend an additional 258 mrem, for a total of 487 mre In particular, the inspector noted that 160 mrem of extra dose was attributable to additional work conducted in response to the failure of some of the sludge to solidif Based on cursory analyses, the RVR-200 vendor initially determined that the sludge from the chemistry/laundry tank was compatible with the solidification process. However, this sludge/paraffin mixture has not yet solidified and staff sluiced this unsolidified mixture from the high integrity container (HIC) into drums stored in the conveyor room. The HIC was moved to the conveyor room and was later prepared for disposal at a low-level waste site. This sludge/parrafin has still not solidified after more than 2 months, possibly due to the presence of detergents, stripping agents, or other materials. The C&RS staff reviewed the contents of this sludge from historical files and determined that this material is not mixed waste. The vendor has since conducted more extensive tests and has determined that this sludge ean be solidified by other methods accepted by low-level waste sites. The C&RS staff have planned to use an alternate solidification method within the near futur Another issue regarding the solidification process was the presence of materials in these
- sludges that was not communicated to C&RS personnel. Plant staff did not notify C&RS staff of the cloth material placed in the drum of containment sump sludge or that spent resin was placed into another drum after the sludge sample was sent for RVR-200 compatability testing. This is another example of poor communications amongst plant employees. This issue of poor communication between various plant departments is further discussed in Section R4.3 of this repor During walkdowns in the Auxiliary Building, the inspectors identified that the entrances to the radwaste packaging area (Room #730) and the component cooling water room were both posted as radiation areas, although only small portions of these rooms actually met the criteria of a radiation area as defined in 10 CFR 20. The inspectors discussed with C&RS management that these postings were not consistent with NRC guidance which states that it is not appropriate to post the entrances to large areas or rooms because the posting does not provide personnel with sufficient information to minimize their exposures from the actual radiation areas. The NRC guidance states that postings should alert individuals of the radiological conditions in their immediate vicinity and that if discrete radiation areas can reasonably be posted, they should be posted. In addition, the inspectors did not identify a radiation area in the radwaste ventilation room, which was posted as a radiation area. The C&RS management stated that these radiation area postings would be reviewed in light of NRC guidanc Conclusions Overall, infrequent evolutions were well managed and expended reasonable radiation dose. However, the sludge solidification work exceeded the original dose estimate, primarily due to the vendor's incorrect determination that the chemistry/laundry sludge was compatible with the solidification process. The practice of posting two large rooms in the Auxiliary Building as radiation areas was inconsistent with NRG guidanc R4.2 Job Performance and ALARA Post Job Reviews for Forced Outage Work Inspection Scope OP 83750)
The inspectors reviewed the applicable review procedure and several ALARA post job reviews from the forced outage work, and interviewed C&RS staff regarding the findings of these ALARA review * Observations and Findings The inspectors noted that the original dose estimate for the forced outage was 4 rem, while the actual dose was 9.67 rem. Although emergent work accounted for 3.13 rem of this final dose, 2.54 rem was due to either underestimated/unanticipated dose by the work planning staff or dose overruns for various jobs. The ALARA post job reviews indicated that the underestimated/unanticipated dose that should have been identified in the original dose estimates was 1.83 rem. The reviewers concluded that the remaining 0.71 rem of the final forced outage dose was dose overrun, due to the job problems discussed below. Thi.s dose overrun was 7.3% of the total forced outage dose, which was similiar to the percentage of unnecessary dose identified by the NRG for the 1996 refuel outag Station staff conducted ALARA post job reviews for outage tasks in accordance with station procedure. The inspectors noted that these reviews were extensive and were also more critical of licens,ee performance than past ALARA post-job reviews (NRG Inspection Report 97004). The following types of problems which contributed to additional dose were identified; equipment malfunctions, lack of job familiarity, lack of temporary shielding, staff not using designated low dose waiting/work areas, too many workers assigned to tasks, and inappropriate placement of high efficiency particulate air (HEPA) filters for jobs. The inspector also noted that respiratory protection was used for the primary coolant pump seal removal, and as a lapel air sample indicated an airborne radioactivity of 15 derived air concentrations (DACs) this decision was appropriat The ALARA staff made several recommendations for future outages which should enable plant personnel to improve dose control. In particular, the staff's recommendations included mock-up training, placing HEPA units closer to work areas to achieve increased flowrate, identifying adequate sources of power for equipment, and ensuring that outage personnel use low dose area *-
- Conclusions Plant personnel performed ALARA post job reviews in accordance with procedure and the reviews demonstrated that the staff was appropriately critical of licensee performance in a variety of areas. The reviewers identified several significant lessons learned and areas for improvement which should enable plant personnel to improve dose contro R4.3 Chemistry Technician Performance and Communications of the Chemistry Department Inspection Scope (IP 84750l The inspectors observed sampling and analyses of the primary and secondary systems and interviewed chemistry personnel regarding various chemistry activitie Observations and Findings The inspectors observed sampling of the primary and secondary systems for liquid and gas samples and noted that the CTs were very knowledgeable of station chemistry and its effects upon various operating systems. The CTs practiced good sampling and ALARA techniques, the function checks for in-line instrumentation were done properly, and sample and in-line data were recorded as required. The chemistry staff maintained the excellent materiel condition of the primary and secondary sampling panels. The fume hood for the primary sampling panel failed the December 1997 face velocity test, and a changeout of the filter media was schedule During interviews, various chemistry staff revealed that they occasionally experienced problems in their communications with other departments and within their department (See Sections R1.4, R2.4, R4.1, R4.4, and R7.1 ). In particular, CTs questioned whether it was proper for them to communicate with control room supervisors. Chemistry staff also indicated that miscommunications between chemistry and operations involved the scheduling for a variety of plant evolutions which affected chemistry performance such as the venting of the volume control tank, the bypassing of demineralizer beds to prevent fouling, the placement of auxiliary feedwater pumps in service at shutdown, and the replacement of demineralizer In discussing this matter with the inspectors, the chemistry manager stated that the CTs had been informed of their responsibility to communicate with operations supervision periodically, and this responsibility would be reiterated to the chemistry staff. In addition, the chemistry manager indicated that another communication problem with the chemistry department involved a report of incorrect PCS boron data which was subsequently questioned by operations personnel. In response, the chemistry staff determined that a wash bottle used to rinse the boron auto-titrator was contaminated with boron, such that the reported results were higher than actual PCS boron concentrations. "'fhis incident demonstrated an effective questioning attitude by operations personnel; however, the chemistry manager acknowledged that the chemistry staff should have initially questioned the data and resolved the anomalous results before reporting the data.
- -
- Interviews with C&RS, operations, and Nuclear Performance Assessment Department personnel indicated that interdepartmental communications has been identified in the past as an area for improvement. And although recent initiatives have improved the performance in this area (See Section R7.2), the C&RS management indicated that there would be continued efforts to improve chemistry department communications both inside and outside the C&RS department, with an emphasis on determining which plant operations would most likely affect the radiological conditions within the plan Conclusions Chemistry staff effectively performed the collection and analysis of various plant system samples and the sampling stations were well maintained. Chemistry personnel have experienced communication problems with other departments. The C&RS management was aware of these communication issues and indicated that there would be continued attention to improve the performance in this are R4.4 Performance of a Chemistry Surveillance for the Safety Injection Tanks Inspection Scope (IP 83750)
The inspectors attended the pre-job briefings and observed activities conducted for the monthly surveillance of the safety injection tanks (MC-11 B). Observations and Findings The inspectors attended the initial pre-job briefing on December 15, 1997, and during this meeting the operations staff discovered that the CT on the "C" shift may not have been able to complete this evolution due to a personal commitment. When questioned by operations staff, the CT stated that he had informed chemistry supervision of this weeks prior to this scheduled surveillance. As there were no CTs on-call, the operations staff properly decided to postpone the MC-11 B surveillance test. The failure of the C&RS staff to address the potential unavailability of this CT for this surveillance and the lack of C&RS notification to the operations staff was another example of poor communications as
- discussed in Section R On the following evening, another CT was brought onto the "C" shift and the test was successfully completed. The MC-11 B pre-job brief covered the duties of the various staff, reviewed the test sequence and acceptance criteria, and emphasized the need for self-checking, attention to detail, and procedural adherence. The health physics technician reviewed the current dose rates, the protective clothing requirements, and the low dose waiting area. The operations staff also allowed time to clarify some confusion regarding the various types of alarms which may have been encountered during the test. The inspectors observed that the CT conducted the sampling, analyses, and control room notifications with good ALARA practice and in accordance with procedure. The inspectors also observed that the operations staff used the low dose waiting area, and the surveillance radiation dose was consistent with past history for this evolution.
18 Conclusions The chemistry staff effectively performed their activities for the monthly MC-11 B safety injection tank surveillance test. In addition, the operations and RP personnel exercised good ALARA practice and the evolution was successfully completed with minimal radiation dos R7 Quality Assurance in RP&C Activities R7.1 Quality Assurance for Laboratory and In-line Instrumentation Inspection Scope (IP 84750)
The inspectors reviewed chemistry quality assurance/quality control (QA/QC) procedures, radiochemical calibrations, and QA/QC data for laboratory and in-line instruments. The chemistry staff was interviewed regarding laboratory QA/QC and general chemistry activitie Observations and Findings The QC data for chemical and radiochemical laboratory instrumentation indicated that the instruments remained within statistical control. The instrument control charts were reviewed regularly, and any biases and unacceptable data were generally identified and corrected in a timely manner. The inspectors noted that the materiel condition of the laboratory instruments was excellent. The QC data for the gamma spectrometry system showed that peak area, width, and location were tracked to ascertain the system's performance. The lower limit of detection tests verified that this system was capable of achieving detection limits well below the Offsite Dose Calculation Manual requirement The calibrations of the radiochemical instruments utilized commercial radionuclide standards which were traceable to the National Institute for Standards and Testing (NIST)
and access to the various radiochemical QC standards was properly controlle However, the inspectors noted that the most recent calibrations for gamma spectroscopy detectors #2 and #3 were conducted approximately 42 months from the previous calibration. Chemistry procedures required a 36 month calibration interval, but allowed a six month extension. The previous radiochemist had recorded the extended date on the calibration *stickers, but did not inform the personnel who had taken on the oversight of these detectors. This was another example of poor communication involving chemistry staff, as discussed in Section R4.3, which resulted in one detector being taken out of service for about two weeks' until the new calibrations were complete. Although the 36 month interval is well beyond the annual recommendation of the American National Standard Institute (ANSI N42.14-1978) and the American Society for Testing and Materials (ASTM E 181-82), the C&RS staff achieved a 100% agreement. in the inter-comparison analyses with the old calibration curves. However, the inspectors noted that the calibration curves for detector #2 changed by more than 5% for several counting geometries and they discussed with C&RS personnel that the calibration data indicated that the 36 month interval appeared to be the practical limit for these calibration ~*
The station utilized in-line instrumentation to measure specific conductivity, pH, sodium, hydrazine, cation conductivity, and dissolved oxygen levels in the secondary syste The function checks, conducted by comparing analysis of grab samples to the in-line instrument reading, demonstrated excellent instrument performance. The inspectors noted that the materiel condition and reliability for these instruments were excellen The station laboratory also participated in commercial QA interlaboratory comparison programs for chemical analyses. These QA analyses were conducted quarterly and each CT participated. For 1997, the plant chemistry results were in agreement with the known values for 84% of the analyses, as the analyses for lithium and iron were problematic in the first quarter. The chemistry staff had purchased new instruments, and the new graphite furnace was optimized to improve the iron analysis. Regarding the lithium analysis problem, C&RS staff prepared a new calibration standard and the CTs were counseled to use the non-linear calibration function on the new atomic absorption instrument. The repeat analyses results were all acceptable. The results for the intracomparison laboratory QA tests showed that 94% of the results were acceptabl The housekeeping in the laboratory was good, and all laboratory reagents and stock solutions were within the prescribed shelf lif Conclusions Overall, the QA/QC and materiel condition of the laboratory and in-line instrumentation were very good, as evidenced by QC checks and QA inter/intracomparison dat However, staff experienced communication problems regarding calibration of the gamma spectrometry system and infrequent problems with various chemical analyse R7.2 Chemistry Audit by Nuclear Performance Assessment Department (NPADl Inspection Scope (IP 84750)
The inspectors reviewed the most recent NPAD audit of the chemistry department and interviewed NPAD staff regarding chemistry performanc Observations and Findings The inspectors noted that the NPAD audit team included two technical specialists from other facilities. The audit consisted of a comprehe,.,sive examination of chemistry organization, procedures, QA/QC practices, sampling, analyses, reagent control, communication, and documentation. The audit team identified discrepancies in logbook entries and review, and noted an improvement in communications with operations staff (Section R4.3). In addition, more complete documentation for the resolution of instrument performance was recommended. The audit also tracked corr~ctive actions to past findings and noted that most of the issues had been appropriately resolved.
- Conclusions The inspectors noted that the NPAD audit team was highly qualified, and the audit of the chemistry program was extensive. The NPAD identified areas for improvement and effectively followed-up past issues to ensure proper resolutio R8 Miscellaneous RP&C Issues R8.1 (Closed) LER 96-011: Control room continuous air monitor (CAM) alarm setpoint was improperly established. On July 30, 1996, a system engineer determined that the control room CAM alarm setpoint was a factor of 60 higher than required 'and that this setpoint was improperly based on beta particulate activity rather than on noble gas activity. The corrective action included installation of a CAM equipped with a noble gas detector and a subsequent calibration of the CAM. The inspector previously verified the use of the correct detector and that the alarm setpoint was appropriately established based on a station gas sample (NRC Inspection Report 97004). This LER was dispositioned as violation 50-255/96009-01, which was closed in the referenced 1997 inspection repor This item is close X1 Exit Meeting Summary The inspector presented the inspection findings to members of licensee management during an exit meetings on December 19, 1997 and January 16, 1998. Plant personnel did not indicate that any materials examined during the inspection should be considered proprietary.
PARTIAL LIST OF PERSONS CONTACTED Licensee M. Banks, C&RS, Manager A. Calloway, Laboratory Supervisor M. Grogan, REMP/RETS Analyst J. Hager, Environmental Support/Respiratory Protection D. Kimble, Reactor Engineer
M. Lee, Chemistry System Engineer R. Margel, Chemistry Supervisor J. McElrath, Senior Chemistry Engineer M. Menucci, C&RS Assessment
M. Moore, NPAD Assessor T. Moore, Chemistry Engineer T. Neal, Environmental Supervisor T. Palmisano, Site Vice President and General Manager L. Phillips, System Engineer C. Plachta, Health Physics Operations Supervisor D. Rogers, General Manager Plant Operations M. Sullivan, Lab Equipment and Analytical Support Analyst P. Prescott, Resident Inspector, Palisades INSPECTION PROCEDURES USED IP 84750, "Radioactive Waste Treatment, and Effluent and Environmental Monitoring" IP 83750, "Occupational Radiation Exposure" LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-255/97016-01 VIO Failure to post the high radiation area in the waste gas surge tank room 50-255/97016-02 IFI PASM hydrogen analyzer is unreliable and lack of verification that the
. PASM delivers representative samples 50-255/97016-03 URI Accident high range iodine filter well beyond shelf life and lack of counting for laboratory analysis of this filter
Closed 96-011 LER Control room CAM alarm setpoint improperly established
A LARA ANSI ASTM CAM CRHVAC C&RS CT DAC ED EPRI FSAR GC HEPA HIC IFI MBD mrem mR NPAD ODCM PASM PC PM PPAC ppb ppm psig QA QC SCBA TS URI VCT VIO WGST ACRONYMS USED As Low As is Reasonably Achievable American National Standards Institute American Society for Testing and Materials Continuous Air Monitor Control Room Heating, Ventilation, and Air Conditioning Chemical and Radiological Services Chemistry Technician Derived Air Concentration Electronic Dosimeter Electric Power Research Institute Final Safety Analysis Report Gas Chromatograph High Efficiency Particulate Air High Integrity Container Inspection Followup Item Mass Balance Determination millirem milliroengten Nuclear Performance Assessment Department Offsite Dose Calculation Manual Post Accident Sample Monitoring Primary Coolant System Preventative Maintenance Periodic Plant Activities Control parts per billion parts per million pounds per square inch gauge Quality Assurance Quality Control Self Contained Breathing Apparatus Technical Specifications Unresolved Item Volume Control Tank Violation Waste Gas Surge Tank
LISTING OF DOCUMENTS REVIEWED Final Safety Analysis Report Sections: 4.3.13 - System Chemical Treatment; 9.9 - Sampling -
System; 9.10.2.3 - Chemical Control; Table 4-16 Primary Coolant Chemistry; 11.5.3.2 -
Radioactive Gaseous Effluent Monitoring System (RGEMS)
Technical Specifications Sections: 3.1 - Primary Coolant System; Table 4.2.1 - Minimum Frequencies for Sampling Tests; 6.5.9 - Secondary Water Chemistry Program; 6.5.3 - Post Accident Sampling Program Offsite Dose Calculation Manual Chemistry Operating Procedure (COP) COP-1, Revision 31, "Primary Coolant System Chemistry".
Procedure COP-11, Revision 25, "Secondary System Chemistry".
Procedure No. CH 1.3, Revision 7, "Laboratory Quality Control Program".
Procedure No. CH 1.7, Revision 3, "Chemistry Trending Program".
Procedure No. CH 3.31, Revision 7, "Primary to Secondary Leak Rate Determination".
Procedure No.* CH 3.39, Revision 2, "Corrosion Product Monitoring".
Procedure No. CH 4.23, Revision 6, "Proportional Counters".
Procedure No. CH 4.24, Revision 5, "Tritium Determination".
Procedure No. CH 4.26, Revision 9, "Total Gas Analysis".
Procedure No. CH 4.27A, Revision 4, "Activated Corrosion Product Analysis Crud-Filtrate".
Procedure No. CH 4.32, Revision 6, "PCS Total Activity".
Procedure No. CH 4.20, Revision 9, "Chemistry Department Organization and Responsibilities" Emergency Implementing Procedure (El) No. El-15.3, Revision 7, "Post Accident Sample Monitoring System (PASM) Operator Training".
Procedure No. El-16.2, Revision 5, "PASM Supplies and Associated Equipment Checks".
Procedure No. El-71, Revision 13, "Post Accident Sampling-PCS Liquid/Gas and Containment Air.
Procedure No. El-7.2, Revision 8, "Emergency Post Accident Analysis".
,.
<' *.
Procedure No. El-7.3, Revision 6, "Hydrogen Analysis of Post Accident Samples".
Procedure No. El-7.4, Revision 64, "Post Accident Gas and Liquid Activity Analysis".
Procedure No. El-7.5, Revision 10, "Boron and Chloride Ion Chromatography Method Post Accident".
Procedure No. El-7.10, Revision 2, "Post Accident Sampling, Radioactive Gaseous Effluent Monitoring".
Procedure No. El-8, Revision 12, "Onsite Radiological Monitoring".
Procedure No. QR-22, Revision 7, "Process Monitor Functional Checks-Quarterly".
PASM System Health Assessments - 1st Quarter 1996 through 3rd Quarter 1997 NPAD Audit PA-97-12, "Palisades.Chemistry Audit", dated 9/22/9 Fuel Integrity Report Cycle 13, November 1997 ALARA Post-Job Review, RWP #971203, "Remove/reinstall insulation for T-72 manway" ALARA Post-Job Review, RWP #971207, "Primary Coolant Pump "A" weld repair
ALARA Post-Job Review, RWP #971216, "Replace degraded RTD cables for Primary Coolant Pump "A".
ALARA Post-Job Review, RWP #971204, "Remove, Transport and Install PCP P-508 seal" ALARA Post-Job Review, RWP #971215, "Measure Seal Gap in Reactor Cavity" ALARA Post-Job Review, RWP #971210, "PCP Seal Flush Filter Changeout"
"Impact of Lithium Control Program on Primary System Materials Corrosion and Shutdown Dose Rates at Palisades", NWT 525-R, dated Septamber 199