ML18043A844
| ML18043A844 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/04/1979 |
| From: | Fisher W, Greger L, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18043A841 | List: |
| References | |
| 50-255-79-06, 50-255-79-6, NUDOCS 7907250211 | |
| Download: ML18043A844 (17) | |
See also: IR 05000255/1979006
Text
I_
U. S. N_UCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION /u~D ENFORCEMENT
REGION III
Report No. 50-255/79-06
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, MI
Inspection Conducted:
March 21-23 and 27-30,
Inspectors:
Approved By:
~~.II~
....., l
- "'
L. J. Rueter
L. R. Grege*~:.XJ<?~
n I -./' ...._1_ . ;-
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I x ; V-i4-/:u."I..
W. L. Fisher, Chief
Fuel Facility Projects and
Radiation Support Section
Inspection Summary
1979
Inspection on March 21-23 and 27-30, 1979 (Report No. 50-255/79-06)
Areas Inspected:
Routine, unannounced inspection of radiation
protection program, including:
qualifications; audits; training;
radiation protection procedures; instruments and equipment; exposure
control; posting, labeling and control; surveys; notifications and
reports; review of progress regarding IE Bulletin 78-08; review of
potential for isolation of containment fan cooling units; review of
two licensee event reports; and review of corrective action regarding
previous noncompliance items.
The inspection involved 141 inspector-
hours on site by two NRC inspectors.
Results:
Of the thirteen areas inspected, no items of noncompliance
or deviations were identified in eleven areas.
Two apparent items
of noncompliance were identified in the remaining two areas (Infraction -
failure to adhere to approved procedures - Paragraph 7; Infraction -
failure to control access to high radiation areas - Paragraph 12) .
79072 5 oc:it/
DETAILS
.*
1.
Persons Contacted
w.
- H.
L.
- J.
J.
- T.
- J.
T.
- G.
- V.
- B.
Hodge, Security Operations Superintendent
Keiser, Plant Operations Superintendent
Kenaga, Environmental Supervisor
Lewis, General Plant Superintendent
Liddell, Training Coordinator
Meek, General Health Physicist
Mills, Radiation Protection Supervisor
Neal, Radioactive Material Control Supervisor
Petitjean, Technical Engineer
Shockley, Plant Health Physicist
Schaner, Operations Supervisor
The inspectors also contacted several other licensee employees,
including members of the technical and engineering staffs.
- Denotes those attending the exit interview.
- Denotes those attending portions of the exit interview.
2.
General
This inspection, which began at 7:00 a.m. on March 21, 1979, was
conducted to examine the licensee's radiation protection program
and related activities for compliance with regulatory requirements.
3.
Licensee Action on Previous Inspection Findings
(Closed)
Infraction 1 (50-255/78-02):
Entries were made intoa
high radiation area (steam generator) without the specific
dosimetry required by procedure H.P. 2.16.
As noted in the
report and the licensee's response dated March 13, 1978, alternate
methods had been implemented to evaluate personal exposures.
However, procedure H.P. 2.16 was not modified to reflect the
alternate methods. It was confirmed during this inspection that
the need to make proper revision to procedures before
implementation of changes had been discussed with the Health
Physics Supervisors.
Corrective action is considered adequate.
(Closed)
Infraction 1 (50-255/78-16):
Radiation levels existed
in an unrestricted area such that an individual, if continuously
present, could receive a dose exceeding 2 millirems in one hour.
These radiation levels existed in the vicinity of the Waste
Storage Building and a nearby trailer.
(See corrective actions
specified below.)
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(Closed)
Defici~ncy, Item 3 (50-255/78-16):
Containers of
radioactive material in a trailer and in the Waste Storage Building
did not bear the required label with the radiation symbol and the
words "Caution, Radioactive Material" or "Danger, Radioactive
Material."
(See corrective actions specified below.)
(Closed)
Infraction 4 (50-255/78-16):
Licensed material stored
in the Waste Storage Building and a nearby trailer was not secured
against unauthorized removal.
(See corrective actions specified
belov:.)
According to the licensee, innnediate corrective action included
posting of signs, roping off the trailers to a distance below
the 2 1IIR/hr isopleth and locking doors to the Waste Storage
Building.
No radioactive IDaterial was found stored in unrestricted
areas during this inspection.
Further, the licensee stated that
radwaste trailers are now loaded in the Waste Storage Building.
All entrances to the building were found to be properly posted
and secured.
Radiation levels in unrestricted areas were within
permissible limits.
The licensee's corrective action is
considered adequate.
(Closed)
Deficiency, Item 2 (50-255/78-16):
Records of surveys
made to evaluate hand exposures received by personnel performing
radioactive filter changes were not maintained.
In a letter
dated September 5, 1978, the licensee stated that evaluations of
hand exposures showed that whole body dose and not the extremity
dose is the limiting factor during filter replacements but that
documentation of these evaluations was not available.
The
licensee further stated that periodic evaluations will be made
and documented in the future.
During this inspection, the
inspectors reviewed records of evaluations of hand exposures during
a dirty waste filter change and a clean waste filter change conducted
necember 13, 1978.
These evaluations confirmed that the whole body
dose was the limiting factor with the extremity exposure (measured
by TLDs on both hands) being less than double that of the whole
body exposure for both filter changes.
The licensee's corrective
action is considered appropriate,
(Closed)
Infraction 5 (50-255/78-16):
The spent fuel pool filters
were changed manually from within the room rather than by remote
IDanipulation of the filter cage assembly from a shielded area
above the room as specified in procedure B.27.4.14.
Involved
personnel were instructed in the correct 1Dethod for filter
changeout by October 17, 1978.
The licensee now bypasses the
f.uel pool filter element.
It appears that the upper part of the
resin bed filter will provide filtering for particulate materials
without significantly reducing the resin service life. When
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,
it is verified tnat the fuel pool filter is not needed, the licensee
may remove the filter. Refer to Paragraph 18 for details of
modifications being made to the clean waste filter system and the
dirty waste filter system.
The licensee's corrective action is
considered appropriate.
(Closed)
Infraction 1 (50-255/78-21):
A worker received 3.26 rems
to the whole body (head) during the first calendar quarter of
1978.
(See corrective actions specified below.)
(Closed)
Infraction 2 (50-255/78-21):
Three maintenance men
worked within a restricted area without au RWP or direct supervision
by the Radiation Protection Group.
One of the workers was
overexposed to external radiation, as noted above.
(See
corrective actions specified below.)
Immediately following the occurrence, training and requalification
sessions were held with RWP-exempt individuals on the topics of
radiation areas and use of the RWP.
Radiation monitoring and
surveillance activities previously assigned to RWP-exempt
individuals were modified.
Following staffing modifications to
provide 24-hour radiation protection coverage, the RWP-exempt
program was replaced on January 2, 1979,. with a new program known
as Limited Radiation Access Authorization (LRAA).
Employees
under this authorization are not permitted to monitor for other
people or to enter high radiation areas without an RWP or
accompaniment by a qualified monitor.
The licensee's corrective
action for these two items is considered appropriate.
(Closed)
Infraction 3 (50-255/78-21):
Proper calibration of three
process.monitors was not accomplished at the prescribed frequency.
The waste gas monitor (RE-1113) calibration on December 6, 1977,
failed to cover the required count rate range.
Recalibration of the
monitor on November 20, 1978, covered a range to 105 count/min,
thereby meeting requirements.
Engineering safeguards gas
monitor (RE-1811), which had not been calibrated for a 26-month
period due to a faulty meter, was calibrated on June 21, 1978,
after replacement of the meter,
The volmne control tank monitor
(~-0202)~ 'Which had not been calibrated since April 1976, was
calibrated on December 21, 1978.
In the future, the Plant Health
Physicist will review calibration records to ensure adequate
calibration, A review by the Plant Health Physicist was completed
by February 16, 1979.
The licensee's corrective action is
considered appropriate *
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I
(Closed)
Unreso],ved Item (50-255/76...09):
Adequacy of criticality
monitoring.
Two"gamma sensitive area monitors installed on the
fuel pool floor provide the criticality monitoring required by
In a letter dated October 27, 1978, the licensee made four
specific commitments to strengthen and improve management control
over the radiation safety program at the Palisades Plant.
These
commitments and their status at the time of the inspection were:
a.
"The General Office Health Physics Group will take a more
active role in the plant health physics program.
Direct
participat~on in procedure development, review of existing
procedures~* and implementation of procedures at the working
level with reports* to the Plant Superintendent and Manager
of Production-Nuclear will occur.
These reports will be
documented.
Procedure review and modification will be
completed prior to the next refueling outage."
No substantive progress had been made regarding this commitment.
The Plant Superintendent had not received any progress reports.
The licensee stated that due to staffing limitations, the
licensee now plans to "contract-out" the development, review,
and implementation of health physics procedures.
b.
"The General Office Health Physics Group will augment existing
health physics training at the plant.
The first such session
was held on October 26, 1978.
The training will include
the principles of AI.ARA~ contents and requirements of
Federal Regulations, use of regulatory guides, radiation
protection practices, and plant technical specification
requirements."
The augmented health physics training program was implemented
in late October 1978 and has continued about nonthly since
that time.
c.
nA plant ALARA review group will be formed for the purpose
of reyiewing plant operational and Eaintenance practices
d,
to minimize radiation exposures.
This group will be composed
of plant health. physics~ operations, and maintenance staff
personnel,
General Office Health Physics personnel will
frequently attend the review* group1Deetings.
Meeting results
will be docU:mented."
No1i:ieetings had been held at the time of this inspection.
Plant and General Office nuclear activities management will
hold a .mee.ting prior to the next refueling outage to review
past progress *on the above three items and consider any
future action,"
The next refueling outage is scheduled for August 1979.
No
1Deetings. had been held at the time of this inspection.
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4.
Organization
The radiation protection organizational structure remains unchanged
from the previous radiation protection inspection.
Four radiation
protection technicians departed in the last year; five technicians
have joined the organization during the year.
The organization
includes the plant health physicist, an associate health physicist,
a radiation protection supervisor, a radioactive materials control
supervisor, and ten radiation protection technicians.
No discrepancies
from the qualification requirements of ANSI NlB.1-1971 were identified.
Twenty-four-hour radiation protection coverage was initiated in
December 1978 to provide better radiation protection control over
offshift 111aintenance activities.
Review of radiation protection
technician training indicated that the criteria for "Individuals
Qualified in Radiation Protection Procedures" were met for the
technicians assigned to the offshifts.
Completion of these
training requirements, however, was not specifically documented.
This item was discussed at the exit interview.
The licensee continues to use chemistry, utility, and contract
radiation protection personnel to augment the plant radiation
protection organization during extended outages.
Contract
radiation protection personnel are selected by the licensee,
based on minimum qualification standards* set by the contractor.
Supervisory contract personnel are utilized to direct the
activities of the contract technicians and coordinate with
licensee supervisory personnel.
Tasks ar~ assigned to the contract
technicians based on their qualifications~ In some cases, entire
jobs are covered by contract personnel, while in other cases,
contract and l*icensee technicians work together on jobs.
According
to licensee personnel, no significant problems have been
encountered with the qualifications of the contract personnel,
although individual conflicts have resulted in some changes in
contract personnel over the past few years.
No items of noncompliance or deviations were identified.
5.
Licensee Audits
The inspector reviewed a Health Physics Technical Audit Report
for the audit condu'cted by three qualified corporate personnel
on October 17-19 1 19.78,
The audit covered various areas of
health physics and environmental surveillance.
No significant
problems were identified in the health physics area.
This audit
appears to meet the requirements of Technical Specification
6,5,2,8 and Procedure QAPP 18~51 for an annual technical
health physics auditi correcting.a problem identified during a
previous inspection._/
1/
IE Insp~ti.on Report No. 50-255/78-25.
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6.
!I
The Health Physics group's internal health physics discrepancy
reports (Form H.P. 2.3.1) for investigation of radiat'ion
protection related procedural discrepancies were reviewed from
April 1, 1978, to this inspection.
It was noted that follow-up
data on some reports were complete.
However, on a few reports,
where need for further investigation was indicated, a follow-up
was either not performed or not timely.
No chronological
numbering system was* used for report identification.
The internal Quality Assurance (QA) organization conducts audits
and reports identified deviations in Q.P. Reports.
These reports
were reviewed for the radiation protection area since the last
routine radiation protection inspection (April 1978).
Q.P. Report 78-15 dated October 17, 1978, identified a failure
to conduct surveys at frequencies specified in plant procedures.
The Plant Review Committee U'RC) recommended that the Radiation
Protection Supervisor acknowledge survey omissions in the
radiation protection log,
Refer to Paragraph 13 for details of
the continuing problems i.:dentified with surveys.
No items of noncompliance or deviations were identified.
Training
Radiation protection orientation training had not undergone
significant change over the last year.
The instructional
requirements of 10 CFR 19 .* 12 are adequately addressed, including
the worker's responsibility to report potential regulatory
violations or unnecessary exposures,
In general, all
individuals authorized unescorted access within the security
fence (protected area) recei:ve the orientation training.
Training is required biennially for plant workers and annually
for others,
Selected review of training records did not identify
any discrepancies from the training requirements.
Two shortcomings in the licensee '*s training program were discussed
at the exit meeting.
Escorted visitors, although they may enter
the radiation controlled plant areas, do not necessarily
receive radiation protection orientati.on training.
Female
employee.S are not necessarily provided the information specified
in Regulatory Guide 8.13 "Instruction Concerning Prenatal
Radi.ati.on Exposure" nor are they asked to acknowledge in writing
that the instruction has been received~ The latter item was
partially addressed in a pre:vious inspecti.on report.]:./
IE Inapection *Report No, 50-255/78 ..... 26,
A formalized rad~ation protection technician training program,
which includes supervised and self instruction and on-the-job
training, has been established.
Completion of the specified
requirements is documented on a standard training record form.
According to licensee personnel, the technician training is
approximately 50% complete for newly hired technicians and
approximately 75% complete for the experienced technicians.
The training program is not defined in the licensee's procedures.
This matter was discussed at the exit interview.
No items of noncompliance or deviations were identified.
7.
Radiation Protection Procedures
The inspectors reviewed changes to the radiation protection
procedures effected since the previous radiation protection
inspection.
The changes did not appear to diminish the
effectiveness of the radiation protection program.
Significant discrepancies in the implementation of several
procedures were identified during the inspection.
The procedures
and the report paragraph detailing the discrepancies are:
H.P. 2.1
H.P. 2.12
H.P. 2.16
H.P. 2.18
H.P. 2.26
Daily Calibration Checks - Revision 5.
(_Paragraph 8)
Routine Radiation and Contamination Surveys -
Revision 8.
(Paragraph 13)
Entry Controls for High Radiation Areas . . *
Revision 6.
(Paragraph 12)
Health Physics Instrumentation Status Board -
Revision 1.
(Paragraph 8)
Calibration of Health Physics Instrumentation -
Revision O.
(J>aragraph 8)
The discrepancies in implementation of these procedures represents
noncompliance with Technical Specifications 6.8.1 and 6.11.1 which
require that radiation protection and radiation instrument
calibration procedures, among others, be implemented and adhered to.
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Instruments and ~uipment
Inventories and calibrations of radiation and contamination
survey instruments, fixed radiation monitors, and continuous
air monitors were selectively reviewed for the period since
the preceding radiation protection inspection.
The following
problems were noted.
Procedure
H.P. 2.26 "Calibration of Health Physics Instrumentation"
(Revision O) *dated August 30, 1978, specifies general calibration
requirements for portable survey instruments and counting
equipment.
Although H.P, 2.26 specifies the use of a tickler
system administered by the Health Physics Clerk for meeting the
semiannual calibration requirements, the tickler system had not
been established at the time of this inspection.
Two survey
instruments (a RASCAL neutron meter and a Ludlum ratemeter) were
discovered by the inspectors to be beyond the specified calibration
interval; the instruments were not tagged for rework/repair.
It
was noted that although H.P. 2.26 specifies a semiannual instrument
calibration frequency, several individual instrument calibraticn
procedures specify quarterly calibration frequencies (H.P. 2.19,
H.P. 2.22, H.P. 2.27, H.P. 2.28, H.P. 2.40, H.P. 2.43).
According to licensee personnel, the semiannual calibration
frequency is being followed.
Procedure H.P. 2.18 "Health Physics Instrument Status Board"
(Revision 1) dated January 10~ 1979~ addresses the use of a
status board to maintain current status of health physics
instruments and equipment,
Although specified in H.P. 2.18, the
calibration due dates were not listed for several instruments,
an incorrect location was listed for RM-14 (Serial No. 335), and
the calibration procedure was not listed for the PS-2,
H.P. 2.18
specifies that the status board should be reviewed weekly to
verify its accuracy.
Evidence of such review was not apparent.
Procedure H.P. 2.1 "Daily Calibration Checks" (Revision 5) dated
September 19, 1977, specifies that calibration check data be
recorded in the daily health physics log .
The daily log entries
did not contain information regarding calibration checks of the
portal monitors or the Ludlum HP-177 ratemeters at the time of
this inspection.
The status of several matters noted during previous inspections
were reviewed during this inspection.
Continuing problems
with operability of the portable continuous air monitors (CAMS) 3; 4;
have greatly hampered their usefulness over the last two years.--
Operability.problems with the automatic sample counter (ASC) used
IE Inspection Report No. 50-255/77-04.
IE Inspection Report No. 50-255/78-*ll *
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=
for determining smear activities date back to 1976.2/ A new ASC,
acquired early i~ 1978, has been inoperable about halr the time.
Four radiation area monitors (RAMs) within containment (RIA 1805,
1806, 1807, and 1808) have insufficient strength check sources
for the background radiation levels in which the monitors are
located.
This problem, which has existed for several years,
prevents the licensee from performing monthly surveillance tests
while the reactor is at power.!!../
These items were discussed
at the exit interview.
The following additional observations were made during this
inspection.
The licensee does not routinely use check sources to
determine operability of survey instruments before each use.
Criticality monitoring on the fuel pool floor is provided by two
gamma sensitive area monitors (RIA 5709 and 2313).
Several
absolute filter equipped vacuum cleaners have been procured and
are available for use within the controlled areas.
Two new
neutron (REM) survey meters were procured to replace the existing
neutron count rate meter, which presented calibration difficulties.
One item of noncompliance was identified involving significant
discrepancies in the implementation of procedures H.P. 2.26, 2.18,
and 2.1.
(See Paragraph 7.)
9.
External Exuosure Control
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Forms NRC-4 and NRC-5 were reviewed for selected Consumers Power
Company and temporary employees at the station for calendar year*
1978.
One individual received an overexposure in the first quarter
of the year based on slightly exceeding the three rem per quarter
limit for whole body dose as reported by the licensee and detailed
in a previous inspection report.21
The total dose at the station in 1978 was about 740 man-rems.
One rather extensive refueling outage occurred early in the year
and a number of short outages occurred later in the year for
replacement of control rod drive seals.
According to the licensee's
records, no doses exceeded five rems for the year.
Only
three individuals exceeded four rems, the highest being 4.45 rems.
Starting in January 1979, the licensee discontinued using vendor
supplied beta-gannna film and NTA neutron film and started using
a TLD system (beta, gamma, and albedo neutron) administered by
the corporate office.
The TLD badge contains two teflon sheets of
TLD material.
Calcium sulfate activated with dysprosium is used
for beta-gannna and lithium fluoride enriched in lithium-7 is used
for neutrons.
The badge has four basic regions:
an open window,
a plastic filter, a copper filter, and a cadmium filter.
A
IE Inspection Report No *. 50-255/76-09.
IE Inspection Report No * 50-255/77-04.
IE Inspection Report No. 50-255/78-21.
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primary region is_first read and the rest of the region serves as
a backup if needed.
This badge system, normally issued quarterly,
will be augmented by station issued TLDs and pencil dosimeters.
The latter two items will be used for short range dose control.
The licensee's procedures and practices for personal neutron
dosimetry were reviewed and found to be consistent with
recommendations of Regulatory Guide 8.14, Revision 1, "Personal
Neutron Dosimeters."
Personal neutron dose records for 1977, based on NTA film, did
not indicate any neutron exposures.
Subsequent licensee
evaluations, made with rem-type neutron dose rate instruments,
indicated that individuals who entered containment in the past may
have received neutron doses greater than those detected by the
neutron film badges.
The individuals with the greatest potential
for neutron exposures were identified as the shift supervisors.
The evaluation indicated that the neutron doses did not exceed
50 mrem in a month for any individual and when added to
previously determined doses does not exceed the NRC exposure limits.
During 1977, about 80 to 90 persons per month were monitored for
neutron exposure.
Containment entry during reactor operation was
the criterion for neutron monitoring of personnel.
The total
annual neutron dose is .est:illlated at five to ten man-rems.
The
licensee's evaluation appears to be adequate.
Independent measurements with a rem type instrument were not
performed.
No items of noncompliance or deviations were identified.
10.
Internal Exposure Control
The licensee's program for controlling internal exposures includes
the use of protective clothing and equipment, reduction of surface
and airborne contamination levels, and utilization of airborne
survey information and stay-time calculations.
Whole body counting
supplements the routine monitoring program to provide retrospective
information regarding airborne exposures.
The inspectors reviewed the whole body counts performed during 1978
and the first two months of 1979.
More than a thousand whole body
counts were conducted during this period.
Personnel are normally
whole b.ody counted upon arrival at the plant if they have received
any recent occupational radiation exposure.
Dependent upon their
exposure potential, licens*ee personnel are whole body counted either
annually or semiannually.
Departure whole body counts are
conducted for personnel whose work involved a potential for ingestion
or inhalation of radioactive material.
The licensee's evaluations
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of whole body counts over the past year were adequate to ensure
compliance with fhe airborne exposure criteria of 10 CFR 20.103.
No airborne exposures greater than 520 MPG-hours were identified.
One individual, still under evaluation, may have exceeded
40 MPG-hours.
This item will be reviewed further during a future
inspection.
The inspectors reviewed the licensee's respiratory protection
program for conformance to the requirements of 10 CFR 20.103 and
No significant discrepancies were
identified.
The licensee's program includes the major items
specified in Regulatory Guide 8.15.
Facepiece fit-testing
(quantitative) is performed biennially.
Training and medical
qualifications are updated annually.
Full face air purifying
and supplied air respirators, supplied air hoods, and self
contained breathing respirators are utilized for respiratory
protection.
Half masks are not used.
The equipment in use is
NIOSH approved.
No items of noncompliance or deviations were identified.
11.
Recent actions taken by the licensee which have a significant
bearing on AL.ARA include:
a.
Modifications are underway to provide more room at access
control to better control the flow of personnel and
equipment to and from the controlled area.
Room is also
being provided for the R,P. Supervisor's office at this
location.
b.
Two full time custodian positions have recently been
established to assist in cleanup of the controlled area.
c.
Modifications of contaminated liquid system filters to permit
remote handling of the filters and fabrication of shielded
filter transport casks are described in Paragraphs 3 and 18.
d.
Replacement of the Radiation Work Permit Exempt classification
with a more restrictive Limited Radiation Access Authorization
(LRAA) is described in Paragraph 12.
12.
Posting, Labeling, and Control
During inspection of the licensee's facilities, the inspectors
examined radiation caution sign postings, high radiation area
access controls 9 radiation work permit usage, and survey postings
for conformance to regulatory requirements and the licensee's
procedures *
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Several problems ~ere identified with the licensee's high
radiation area a;cess controls.
Although 10 CFR 20.203(c)(2)
requires that positive controls be exercised over entries to
areas containing radiation levels which could result in a whole
body exposure exceeding 100 mrems in one hour, the licensee
changed the criteria for initiating such controls to 1000 mR/hr
at the beginning of 1979, without receiving authorization from the
NRC to deviate from 10 CFR 20.203(c)(2).
Several such areas
existed at the time of this inspection.
For example, the clean
waste receiver tank pump room (590' level) was posted as a high
radiation area on the status sheet (dated March 21, 1979) at the
entrance to the area with general area radiation levels of 200
mR/hr.
The room was unlocked; the high radiation area within the
room was defined with radiation rope and signs.
Similarly, the
door to the boronometer and 602 pipeway entrance room (590' level)
was unlocked on March 21, although the status sheet (dated
March 19, 1979) listed general area radiation levels of 200 mR/hr.
In addition to these areas, the spent resin storage tank and the
volume control and radwaste demineralizer rooms were discovered
unlocked on March 28.
Both areas were posted as containing
radiation levels greater than 1000 lllR/hr (up to 15,000 lllR/hr)
on status sheets at the entrances to the areas.
The above
inspection findings represent noncompliance with 10 CFR 20.203(c)(2).
Additional problems with high radiation area controls were:
(1) HRA controlled keys were stored in an unlocked, and often
unattended, cabinet in the H., P. office; (2) at least one
unaccounted for HRA key was discovered in the possession of a
plant employee during the inspection; (3) HRA keys are not always
returned to the key cabinet upon completion of the required usage.
(Log entries show that one key was checked out for approximately
three days instead of being returned at the completion of the
shift.); and (4) Procedure H.P. 2.16 (Revision 6) "Entry Controls
for High Radiation Areas .** " dated February 14, 1979, is not
routinely followed.
Entries are not routinely approved by the
Health Physicist or Radiation Protection Supervisor; Form H.P. 2.16-1
is not always completed; and the control room is not always notified
of entries and exits from the HRAs.
An entry to the clean waste
filter room (590' level) by two licensee personnel during this
inspection included the discrepancies from H.P. 2.16 noted above and,
in addition, the individuals were not equipped with the personal
dosimetry devices specified in H.P. 2.16.
Radiation work permits (RWPs) are required for work performed
under certain radiological conditions. It was noted that
individuals included on an RWP are not required to acknowledge
their awareness of the RWP conditions. It was also noted that
RWP terminations were not timely during a two week period in
April 1979.
A previous RWP-exempt classification has been
replaced by a more restrictive Limited Radiation Access
Authorization (LRAA).
Certain plant employees who have completed
specified radiation protection training requirements are permitted
to enter the radiation controlled areas of the plant and perform
certain routine operations without an RWP under this program.
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1
The documents reRuired to be posted pursuant to 10 CFR 19.11 were
noted to be posted as required.
One item of noncompliance was identified.
13.
Surveys
Records of various surveys for contamination, direct radiation,
and airborne activity were reviewed for the period July 1, 1978
through March 27, 1979.
In general, survey records of the past
three months were reviewed in detail.
Health Physics Procedure
H.P. 2.12, "Routine Radiation and Contamination Surveys,"
specifies techniques and requirements for daily, weekly, and
monthly radiation and contamination surveys.
Daily surveys of
about 30 areas, concentrating primarily on the 590' and 611'
elevations of the Auxiliary Building, are being conducted
timely.
In general, when elevated levels of radiation or
contamination were identified, followup action appeared proper
and timely.
Weekly surveys of about 40 areas, again concentrating primarily
on the 590' and 611' elevations of the Auxiliary Building,
(but at different locations from the daily surveys) have been
conducted timely since January l~ 1979.
However, records
indicate that only seven weekly surveys were conducted in the
last six months of 1978.
These weekly surveys were conducted
on July 21 and 28, August 3 and 14, October 20 and 26, and
November 23, 1978.
Review of records indicated that the specified monthly surveys
for radiation and contamination levels at about 100 locations
in "clean areas" of the plant had not been performed during the
period of review, July 1, 1978 through :March 27, 1979.
Technical Specifications 6.8.1 and 6.11.l require establishment,
approval, maintenance, implementation, and adherence to radiation
protection procedures.
Radiation Protection Procedure H.P. 2.12
requires weekly radiation and contamination surveys at specified
locations in the Auxiliary Building and 111onthly radiation and
contamination surveys in specified clean areas." The* licensee
appears to be in noncompliance with these technical specifications
in that required monthly surveys were not performed during the
period July 1 1 1978, through March 27, 1979, and only seven of
the required weekly surveys were performed during the last six
months of 1978.
(See Paragraph 7.)
The inspector also reviewed records of various other surveys,
including:
airborne surveys in conjunction with updating area
status sheets twice monthly; special air samples in containment
(16 in the past three*:months); and neutron and gamma radiation
and contamination surveys in containment in November 1978.
No
particular prob.lems were identified,
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For in-plant airqorne activity evaluations the licensee uses a
Scott charcoal cartridge which contains TEDA impregnated carbon
for adsorption of radioiodine with an efficiency of 90%.
The
licensee also uses an efficiency of 90% for the particulate
filters used.
The inspector also reviewed the licensee's sealed source inventory
and leak test records for 1978 and 1979 to date.
All sources
were accounted for and the leak tests showed no evidence of
radioactive leakage.
One item of noncompliance and no deviations were identified.
©
14.
Notifications and Reports
Based on statements made by licensee representatives and
substantiated to the extent of records reviewed by the inspectors,
it was concluded that the licensee has experienced no theft or
loss of licensed material.
A reported overexposure in early 1978
was reviewed during a previous inspection ... ~/
Records reviewed for selected Consumers Power Company employees
and contractor 2mployees who had terminated in the past six months
showed that timely reports required by 10 CFR 20.408 had been sent
to workers.
No items of noncompliance or deviations were identified.
15.
Licensee actions regarding radiation levels in areas adjacent
to the fuel element transfer tube were partially reviewed during
a previous inspection *. .2/
The licensee plans to measure radiation
levels in several areas while transferring fuel during the next
refueling outage.
Final review of this 111atter will be completed
during a future inspection.
No items of noncompliance or deviations were identified.
16.
Containment Fan Cooling
8/
!/
The inspectors reviewed the containment fan cooling system to
ensure that high external radiation levels would not interfere
with the proper functioning of the system.
This is not a potential
problem with the Palisades Plant due to the service water monitor
location (underground in the Turbine Building) and function
(alarm but no trip action).
No items of noncompliance or deviations were identified.
Ibid *
Ibid.
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17.
LER 78-33 and LER 78-40
The inspectors r.eveiwed the radiological aspects of ~wo
occurrences reported by the licensee.
LER 78-33 involved a leakage of about 0.014 curies of radio-
active gas (principally Xe-133) between September 26 .and
October 10, 1978 from Waste Gas Decay Tank T-68B.
The tank
was taken out of service and is still out of service while
various valves or valve components are replaced and tests
conducted using air to identify and correct the leak.
The
licensee is currently awaiting receipt of certain valve
components.
The inspector reviewed the analyses and cal-
culations for quantification of the release and identified
no problems.
No release rate. limits were exceeded.
LER 78-40 involved leakage on November 28, 1978, of about
4.3 curies of radioactive gas (principally Xe-133) from an
open surge tank sight glass drain valve when the volume control
tank (VCT) was vented to degas "the prirmry coolant system.
The venting of the VCT was secured upon receipt of a gas monitor
alarm.
The inspector reviewed the analyses and calculations for
quantification of the release.
No problems were identified.
No health or safety consequences resulted from these occurrences.
Other aspects of these.events are being followed by the NRC
. Operations inspector.,
No items of noncompliance or deviations were identified.
18.
Modifications in Progress on Clean and Dirty Waste Filter Systems
A shielded filter cask and an outer shielded cask are being
constructed for removal and disposal of clean waste filter
cartridges.
The filter cask provides about three inches of
lead while the transfer cask has about four inches of lead
on the sides and a six-inch steel lid. Rerouting of piping
is planned to change the location of the dirty waste system
filter to the clean waste filter room.
This will permit use
of the new filter and transfer casks for removal of dirty
waste filters.
The licensee estimates these modifications
will be completed (including preparation and approval of
procedures) by October 1, 1979.
After the modifications are
completed, the only liquid waste filters that will not be
handled remotely will be the laundry filters which have
maximum radiation levels of 5-10 mR/hr at contact.
No items of noncompliance or deviations were identified *
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19.
--
Exit Interview ..
The inspectors met with licensee representatives (denoted in
Paragraph 1) at the conclusion of the inspection on March 30,
1979.
The inspectors summarized the scope and findings of the
inspection.
In response to certain items discussed by the
inspectors, the licensee:
a.
Acknowledged that only one of the four commitments made in
the letter dated October 27, 1979, had been implemented.
as of the inspection date.
(Yaragraph 3)
b.
Stated that documentation of training for "Individuals
Qualified in Radiation Protection Procedures" and Regulatory
Guide 8.13 prenatal exposures would be considered.
(Paragraphs 4 and 6)
c.
Acknowledged the inspectors' comments regarding Procedure
H.P. 2.3 "Investigation of Radiation Protection Related
Procedural Discrepancies" (Revision 1) dated February 14,
1978, and agreed to review the procedure with regard to:
(1)
type of occurrences to be included in the reports,
(2) identification of reports by a numbering system, and
(3) timely evaluations and followups where needed.
(Paragraph 5)
d.
Acknowledged the inspectors' comments regarding radiation
protection orientation training for escorted visitors and
stated that a gradated training program would be considered.
(Paragraph 6)
e.
Acknowledged the inspectors' comments regarding the observed
lack of a formally defined training program for radiation
protection technicians.
(Paragraph 6)
f.
Acknowledged the inspectors' comments regarding the noncompliance
items.
(Paragraphs 8, 12, and 13}
g.
Agreed to pursue resolution of the operability problems with
the CAMs, ASC, and RAM check sources.
(Paragraph 8)
h.
Acknowledged the inspectors' comments regarding improvements
evident in the whole body counting program and stated that
followup would continue for one individual suspected of
exceeding 40 MPC-hours intake.
(Paragraph 10)
i.
Stated that high radiation area controls would be reviewed
and revised as necessary.
(Paragraph 12)
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