IR 05000255/1999014
| ML18066A655 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/23/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18066A654 | List: |
| References | |
| 50-255-99-14, NUDOCS 9910010374 | |
| Download: ML18066A655 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION Docket No:
License No:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved by:
9910010374 990923 PDR ADOCK 05000255 G
PDR REGION Ill 50-255 DPR-20 50-255/99014(DRS)
Consumers Energy Company Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530
. August 31 - September 1, 1999 D. Nelson, Radiation Specialist Gary L. Shear, Chief, Plant Support Sranch Division of Reactor Safety
EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/99014(DRS)
The purpose of this inspection was to review the Chemical and Radiological Services Department's (CRSD) on-line planning and scheduling program and CRSD's involvement in the planning and scheduling of the refueling outage scheduled to begin in October 1999. The inspection also included a review of planned Nuclear Performance Assessment Department (NPAD) oversight of CRSD performance during the outage and a tour of the facility. The following conclusions were reached:
The CRSD's on-line (non outage) Planning and Scheduling program provided effective coordination and established appropriate radiological control provisions over on-line work activities, (Section R1.1 ).
The CRSD was effective in ensuring that radiation protection issues and As-Low-A~
Reasonably-Achievable (ALARA) controls were integrated into the planning and scheduling of the 1999 refueling outage. (Section R1.2).
- NPAD's planned oversight of CRSD activities during the 1999 refueling outage was well planned and of sufficient scope to assess the performance of the radiation protection program. (Section R1.3).
- Report Details IV. Plant Support R1 Chemical and Radiological Services Department (CRSD) Radiological Planning and Scheduling Program and Nuclear Performance.Assessment Department (NPAD) Oversight of Outage Activities
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R1.1 On-line CRSD Planning and Scheduling Inspection Scope (83750)
To determine the status of the CRSD ori-line radiological planning and scheduling program, the inspector reviewed the Palisades Work Control Process "13 Week Schedule Program Planning & Scheduling Guidelines 2.0" Revision F, October 1, 199 The inspector also attended the T-3 and T-4, T-1 and T-2 and T-0 on-line scheduling meetings, the daily CRSD Morning Meeting and the daily Production Team Meetin The inspector also interviewed the CRSD radiological Scheduler and Planner and members of CRSD managemen Observations and Findings A thirteen week schedule was used to plan and schedule on-line work request Although the process for scheduling on-line work as described in the Guidelines is detailed and complex, the application was straight forward and logically implemente All new work requests were sent to the Operations Department to be screened and assigned a priority number. Following Operations Department review, the requests are reviewed at the daily Production Team Meeting and if approved were put into the schedule and sent to the facility planners to be processed. In general, weeks T-12 to T-8 (week 12 to week 8 look ahead) were set aside in the schedule to allow Engineering an opportunity to provide input into the work requests. Weeks T-8 to T-4 were set aside for parts procurement and by week T -4 the work should have been fully planned and
"available for schedule". During weeks T-3 to T-2 the schedule was finalized and the work performed during week T-0. Throughout the process scheduling meetings (T-3 and T-4, T-2 and T-1, and T-0) were regularly held to discuss the schedule and make necessary change The CRSD Planner and Scheduler track and provide input into the thirteen weeK--
schedule by reviewing all new work requests, by attending the scheduling meetings and by working closely with the station planners. Meetings attended.by the CRSD Scheduler and/or Planner included the look ahead meetings, the daily Production Team meeting, the weekly Supervisors Meeting, the weekly CRSD Time Out Meeting and the daily CRSD morning meeting. As planning tools, the CRSD Planner and Scheduler also generated an Eight Week Look Ahead Report and a T-1 Dose Estimate Report for managers and supervisors. The CRSD Planner or Scheduler also reviewed all work requests to identify radiation protection issues and/or the need for ALARA planning to ensure that no work would be perfornied-(available for schedule) until the work package has had a been reviewed by the CRS.
The inspector attended a number of scheduling meetings and observed that the participants were attentive, took an active part in discussions and appeared to be very knowledgeable of their phase of the thirteen week schedule. The inspector attended the meetings with the CRSD Scheduler and observed that the Scheduler was very cognizant of all phases of the thirteen week schedule and was an active participant in the proceedings. Following the meetings, the inspector discussed the thirteen week schedule with non-CRSD schedulers, planners and members of the staff. During those discussions the inspector was told that dose had become a primary factor in the planning and scheduling of on-line work indicating managements' commitment to reducing station dos * Conclusions The CRSD's appeared to be effective in ensuring that dose reduction considerations became an integral part of the on-line work scheduling and planning process.
.,J R1.2 CRSD Outage Planning and Schedulin Inspection Scope (83729)
The inspector reviewed the draft Palisades 99 Refueling Outage Schedule and th "1999 Refout Engineering Assistance Request for Dose Reduction". The inspector alsp interviewed the CRSD Planner and Scheduler, members of the CRSD ALARA staff, the Lead Outage Coordinator and CRSD management regarding planning for the 1999 refueling outag Observations and Findings
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Planning for the 1999 Refueling Outage due to begin on October 15, 1999, began shortly after the completion of the 1998 Refueling Outage in the spring of 1998. By early fall of 1998, the scope of the 1999 outage had been determined and the major activities identified. In October 1998, planners within the CRSD ALARA Planning staff.
were assigned to specific dose significant projects including work on the steam generators, refueling activities on the refueling floor and outage construction support. In January 1999, the outage scope was expanded to include repair of the "A" Primary Coolant Pump casing and an ALARA Planner was assigned to that project. In August 1999, the final outage scope and schedule were finalize In preparation for the outage, the ALARA Planning Group was expanded *to include one supervisor*, three ALARA Planners an*d two radiation work permit (RWP) writers. In addition, a radiation protection technician from the CRSD Radiological Services Group was assigned to provide additional ALARA planning support for the primary coolant pump project. The ALARA supervisor and planners indicated that most of the planning for the routine outage activities had been completed and the staff was concentrating on dose significant project planning and the completion of outage RWPs. Planning activities for the dose significant projects included but were not limited to attending the major outage planning sessions, reviewing contractor procedures for dose reduction opportunities and meeting with the contractors to discuss worker practices and outage dose. Since contractor dose historically contributed a significant portion of the outage
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dose, contractor involvement was seen as critical to meeting the 150 person-Rem outage collective dose goa The ALARA Planning Group also recommended a number of dos.e saving initiatives for the 1999 outage. Some of the initiatives adopted included zinc injection, "Back to Basics Training" for contract workers, the purchase and increased use of video/audio equipment and installing new permanent shielding. Another initiative approved by management was the round the clock posting of an ALARA Planner at the access point to the radiation controlled area (RCA) to screen all worker entries into the RCA. The ALARA would also provide enhanced support for ongoing outage activitie To ensure that the ALARA Planning group is aware of all emergent work during the outage, the Lead Outage Coordinator was tasked with screening all emergent work requests to determine if the work was within the outage scope and to notify the ALARA Planning Group if the work is deemed within the scope of the outage. To ensure that no
.emergent work was performed without ALARA input, the work would be withheld from the outage schedule until the ALARA Planners indicated in the work package that the work request had been reviewe Conclusions The CRSD ALARA Group's involvement in the planning* for the 1999 Refueling Outage appeared to be well planned and executed. The adoption of a number of dose reduction initiatives indicated management's commitment to reducing dose during the 1999 Refueling Outag R1.3 NPAD Planned Oversight of CRSD Activities During the 1999 Refueling
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. Inspection Scope (83750)
The inspector reviewed "NPAD RF099 Assessment Plan", the detailed plan for NPAD oversight of the 1999 Refueling Outage and interviewed members of the NPAD staf Observations and Findings The NPAD Assessment Plan described in detail the areas that would be assessed during the 1999 refueling outage. Many of those areas included direct observation of
. CRSD and radworker activities during the outage. The plan called for assessments of *
contractor training/assimilation, RWP content, radworker practices, postings/boundaries, work control/coordination, radiation technician performance, dose/contamination control and tracking and *adherence to the outage schedule. Although the scope of these assessment activities appeared to be very ambitious, the NPAD staff indicated that there was sufficient staff with radiation protection experience and training to complete the scope of the plan.
'. Conclusions NPAD oversight of CRSD activities during the 1999 Refueling Outage appeared to be well planned and staffe X1 Exit Meeting Summary The inspector presented the inspection findings to members of licensee management during an exit meeting on September 1, 1999. Plant personnel did not indicate that any materials examined during the inspection should be considered proprietar '
PARTIAL LIST OF PERSONS CONTACTED Licensee E. Bogue, C&RS, Manager D. Burdette, NPAD S. King, Licensing D. Malone, Licensing G. Sturm, ALARA Coordinator J. Lennartz, Senior Resident Inspector, Palisades IP 83750 IP 83729 None A LARA CRSD NPAD RP RWP INSPECTION PROCEDURES USED
. "Occupational Radiation Exposure"
"Occupational Exposure During Extended Outages" LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED ACRONYMS USED As Low As Is Reasonably Achievable Chemical and Radiological Services Department * *
Nuclear Performance Assessment Department Radiation Protection Radiation Work Permit PARTIAL LISTING OF DOCUMENTS REVIEWED Work Control Process "13 Week Schedule Program Planning & Scheduling 4uidelines 2.0" Revision F, October 1; 1998 -
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Palisades 99 Refueling Outage Schedule (draft)
1999 Refout Engineering Assistance Request for Dose Reduction, Recommended Dose Saving Initiatives for the '99 REFOUT
13 Week Schedule Program, T-0 Schedule NPAD RF099 Assessment Plan 7