ML18044A665
| ML18044A665 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/06/1980 |
| From: | Fisher W, Heuter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18044A662 | List: |
| References | |
| 50-255-79-19, NUDOCS 8003210043 | |
| Download: ML18044A665 (18) | |
See also: IR 05000255/1979019
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/79-19
Docket No. 50-255
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:
November 8-9 and 14-16, 1979
/~
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/
, , ti:i ;\\. (,_ ~"
Inspector:~~~ J. Rueter
1/l t r:j~\\.l- L
Approved By:
W. L. Fisher, Chief
Fuel Facility Projects and
Radiation Support Section
Inspection Summary
License No. DPR-20
1/~* JJ=c
Inspection on November 8-9 and 14-16, 1979 (Report No. 50-255/79-19
Areas Inspected:
Routine, unannounced inspection of radiation protection
program associated with the refueling outage, including:
radiation pro-
tection procedures; advance planning and preparation; training; external
exposure control; internal exposure control; ALARA; posting and control;
radioactive ~nd contaminated material control; surveys; IE Bulletin 78-08;
IE Information Notice 79-08; audits; instruments and equipment; secondary
system demineralizer resin; and IE Bulletin 79-19.
The inspection in-
volved 47.5 inspector-hours on site by one NRC inspector.
Results:
Of the fifteen areas inspected, one apparent infraction ident-
ified in the area of external exposure control involved the overexposure
of an eighteen-year-old (Paragraph 7); one apparent infraction indentified
in the area of radiation protection procedures involved a failure to
follow procedures (Paragraph 8); and one apparent infraction identified
in the area of the secondary systems demineralizer resin involved failure
to m~ke proper evaluations for presence of radioactive material in plant
refuse before release for burial. (Paragraph 17)
800321001./-:S
DETAILS
1.
Persons Contacted
- J. Lewis, Plant Manager
- H. Keiser, Superintendent of Operations and Maintenance
T. Neal, Radioactive Material Control Supervisor
- T. Meek, Plant Health Physicist
- H. Palmer, Technical Superintendent
- R. McCaleb, Quality Assurance Superintendent
- P. Botts, Quality Assurance Engineer
L. Kenaga, Environmental Supervisor
- B. Jorgensen, NRC Resident Inspector
The inspector also contacted several other licensee employees.
- Denotes those attending the exit interview.
2.
General
This inspection, which began at 8:00 a.m. on November 8, 1979, was
conducted:
to examine the licensee's radiation protection program
during a refueling outage; to review the licensee's actions taken
in response to IE Bulletin No. 79-19, "Packaging of Low-Level Radio-
active Waste for T1,nsport and Burial"; and to review a previously
identified matter -
of landfill disposal of powdered resins (Powdex)
from the condensate demineralizer system (secondary system).
3.
Licensee Action on Previous Inspection Findings
In a letter dated October 27, 1978, the licensee made four specific
commitments to strengthen and improve mangement control over the
radiation safety program at the Palisades Plant.
These commitments
and their status at the 2fme of a previous inspection were detailed
in an inspection report -
.
The commitment regarding training had
been implemented at that time.
Regarding the procedure review and
modification before the next refueling outage, the licensee con-
tracted with Proto Power Management Corporation to identify for
elimination any contradictions in various procedures and to develop
a "Radiation Work Practices Handbook" to provide an overview of radi-
ation protection practices for other than Health Physics personnel.
(Intended primarily for supervisors of maintenance crews and for all
limited access authorized individuals.)
This handbook covers the
subjects of personnel protection, contamination control, shielding,
1/
IE Inspection Report No. 50-255/79-16.
~/ IE Inspection Report No. 50-255/79-06
- 2 -
work planning etc.
This contractor also tabulated procedural
commitments, which are being developed into a check-off sheet to
ensure timely performance and to provide for documenting any prob-
lems and subsequent corrective action.
Regarding the plant ALARA
review group, to review plant operational and maintenance practices
to minimize radiation exposures, the group was established and has
held three meetings beginning June 13, 1979.
The fourth commitment
was fulfilled by a meeting of Plant and General Office Nuclear Ac-
tivities Management personnel on August 23, 1979, before the refueling
outage to review progress on the other three commitments and to con-
sider future action.
The minutes noted fulfillment of the commitments
and listed some additional subject matter to be covered in training
following the refueling outage.
The inspector has no further questions at this time regarding ful-
fillment of the referenced commitments.
(Closed) Infraction 1 (50-255/79-06):
Several high radiation areas
were not locked or equipped with control devices.
Further, positive
control was not exercised over entries to these and other locked HRAs
by failure to routinely follow HRA access controls specified in
Procedure H.P. 2.16, and failure to exercise positive control over
HRA keys.
During the inspection it was confirmed that the licensee
~,s 4
7aken corrective actions as specified in the letters of response
-
-
to the infraction.
These actions included:
application and
receipt of the Technical Specification Amendment No. 48, dated
May 15, 1979, authorizing use of an alternate method for controlling
entry to high radiation areas; receipt and installation (installation
was completed during the inspection) of a new uniform set of locks
and keys to replace three separate series of locksets and keys pre-
viously used throughout the plant; procedure revisions to reflect
change in the system; training in use of the revised system; and
daily check of locked doors to ensure they are secured.
Corrective
action taken appears adequate.
(Closed) Infraction 2 (50-255/79-06):
Significant discrepancies in
the implementation of procedures involving daily instrument checks,
surveys, HRA controls, instrument controls, and the instrument status
board were identified.
During the inspection, it was confirmed that
the licensee57as taken the corrective actions specified in the letter
of response -
to the infraction.
These actions included:
reviewing
and revising calibration procedures for consistency in calibration
frequency (generally semiannual); listing all portable Health Physics
3/ D. P. Hoffman to J. G. Keppler, June 27, 1979 and
4/ D. P. Hoffman to J. G. Keppler, September 18, 1979
~/ D. P. Hoffman to J. G. Keppler, June 27, 1979
- 3 -
4.
instruments on the Health Physics Instrument Status Board which is
reviewed weekly for purposes of updating with pertinent information
on each instrument; and establishing and implementing a separate
check sheet (H.P. 2.1-1) for verifying daily instrument checks.
Measures taken regarding HRA controls are covered above in follow-up
for Infraction 1.
The licensee has deleted the procedural require-
ment for weekly and monthly contamination and radiation surveys, but
continued to perform them except during periods of heavy workload as
during an outage.
The deletion was based on past survey results
indicating no significant problems identified in areas covered by
weekly and monthly surveys.
However, after discussion of this matter
the licensee has agreed to slightly expand area coverage of the cur-
rent procedurally required daily surveys and to procedurally require
monthly surveys of other areas.
This corrective action is considered
adequate.
Radiation Protection Procedures
Numerous changes to radiation protection procedures, including re-
visions, temporary changes and a couple of entirely new procedures
for the period July 26, 1979 through November 1, 1979, were reviewed
by the inspector.
Some minor discrepancies and a few changes needed
for clarification were identified in the review of radwaste proce-
dures, also covered as a part of this inspection, in particular the
new H.P. 2.44 "Low-Level Waste Packaging" and the revised H.P. 6.20
"Radioactive Waste Shipments."
A consultant reviewed procedures
earlier in the year as noted in Paragraph 3.
All procedures showed
requisite approvals and appeared to be compatible with technical
specifications and the FSAR.
No items of noncompliance were noted
in procedures.
However, one apparent item of noncompliance was observed regarding
failure to follow procedures, as noted in Paragraph 8.
5.
Outage Planning and Preparation
The inspector reviewed outage planning by the radiation protection
department, including participation in station outage planning,
written procedures for various aspects of outage work, and the
application of previous outage experience.
Planning and prepara-
tions appeared to be significantly improved over the last refueling,
notwithstanding the licensee is currently short-handed two H.P.
technicians and that some difficulty was experienced in obtaining the
number of contract technicians wanted.
In interviews with personnel,
there was some indication of insufficient technicians to provide
adequate direct H.P. coverage in containment early in the outage, but
the situation apparently improved after the matter was brought to the
attention of H.P. management .
- 4 -
-
I
Providing of additional space and redesign of the access control area
has significantly reduced the congestion problem noted at the time of
the last refueling inspection and has improved control of personnel
and contamination.
An H.P. representative was assigned to the outage scheduling group
about two months before the outage and continued to work in that
capacity throughout the outage.
Another H.P. representative was assigned to coordinate the radiation
protection activities of two major outage jobs.
These jobs involved
steam generator work and replacement of boric acid heat tracing.
No items of noncompliance or deviations were identified.
6.
Training
The licensee's radiation protection orientation training for new
personnel still consists of a video tape presentation, which includes
basic radiation protection principles and practices and covers the
required instructional items specified in 10 CFR 19.12.
In early November the license completed training female employees
regarding prenatal exposure as outlined in Regulatory Guidg18.13.
This training and records of attendees are now documented -
.
The licensee has considered II and decided to document the training
and certification of Individuals Qualified in Radiation Protection
Procedures" who may provide immediate H.P. coverage on all shifts.
This will be done by planning a letter of certification in each
certified individual's file.
The licensee has not yet addressed the consideration ~/ of a grad-
uated training program for escorted visitors.
Regarding the lack of a formally defined training program for radia-
tion §yotection technicians noted at the time of a previous inspec-
tion -
, the licensee is currently revising the administrative pro-
cedures to outline specific areas of H.P. training and provide guid-
ance in documentation over and above that currently specified in the
general orientation.
No items of noncompliance or deviations were identified.
6/
IE Inspection Report 50-255/79-06
J/
Ibid
B/
Ibid
~/ Ibid
- 5 -
7.
External Exposure Control
The licensee's procedures for exposure control and implementation
of these procedures were reviewed.
The system is not significantly
changed from that used in the past, except for policy regarding
eighteen-year-old workers, as will be noted below in this section.
/
The inspector reviewed plant records and interviewed plant personnel
regarding an overexposure of an eighteen-year-old contractor employee.
The determination that an overexposure occurred was made September 27,
1979.
The resident inspector was notified and he in turn notified
the NRC regional office on October 2, 1979.
The licensee submitted
the "30 day report" (required by 10 CFR 20.405) on October 26, 1979.
Information provided in the report was verified.
The eighteen-year-old
was exposed to about 1.7 rem during the third quarter of 1979.
This
is in excess of the 1.25 rem per calendar quarter limit allowed by 10
CFR 20.101 for eighteen-year-olds.
This constitutes an item of non-
compliance.
The cause of the overexposure was an oversight by the person conduct-
ing paper work for limiting exposure.
He failed to properly note
the age of the worker and the limitations placed on eighteen-year-old
workers.
As a corrective measure, 10 CFR Part 20 requirements and
licensee procedures covering limits of exposure were reviewed with
this individual and with the other radiation protection personnel.
Also, exposure limits for all other eighteen-year-old workers were
reviewed.
Further, the licensee has revised plant procedures to
exclude eighteen-year-olds from radiation work.
Also the licensee
has limited the number of radiation protection personnel who may
assign exposure limits.
The licensee did not have a compilation of total exposure received
to date during the outage.
The outage was being extended several
weeks due to anchor bolt testing.
One item of noncompliance was identified involving overexposure of
an eighteen-year-old worker.
8.
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 supple-
ments the routine monitoring program to provide retrospective infor-
mation regarding airborne exposures.
The inspector reviewed the whole body counts performed from March 2,
1979, through November 10, 1979.
More than 900 whole body counts
- 6 -
l
were conducted during this period, including about 300 people counted
during the current outage.
Only the preliminary count data were
available on about 268 people counted since October 1, 1979.
Per-
sonnel are normally whole body counted upon arrival at the plant if
they have received any recent occupational radiation exposure.
Dependent upon their exposure potential, licensee personnel are whole
body counted either annually or semiannually.
Departure whole body
counts are to be conducted for personnel whose work involved a poten-
tial for ingestion or inhalation of radioactive material.
The licen~
see's evaluations of whole body counts conducted over this period
were adequate to ensure compliance with the airborne exposure criteria
of 10 CFR 20.103.
No airborne exposures greater than 520 MPC-hours
were identified.
Further evaluation is needed to determine if one individual exceeded
40 MPC-hours.
The individual was a contractor employee involved in
inspection work in containment.
Four whole body counts conducted on
October 10 and 11, 1979, demonstrated that much of the initial activity
was due to minor external contamination, subsequently removed.
This
item will be reviewed further during a future inspection.
At the time of a previous inspection lO/ it was noted that one in-
dividual still under evaluation at that time may have exceeded 40
MPC-hours.
The evaluation has since been completed and it was con-
cluded that the worker received an airborne exposure of about 44
MPC-hours during a seven day period as a result of work in the decon
room on September 5, 1978, involving a primary coolant seal rebuild-
ing job. It is believed that carbon rings used in the seals may
have dried and released readily dispersible carbon particles with
attached activity during the deconning and rebuilding process.
Six
whole body counts were conducted on the individual from September 5,
1978, to February 21, 1979.
Actions taken to ensure against recur-
rence of this problem are included in the licensee's evaluation
package on file at the plant.
The actions appear to fulfill the
requirements of 10 CFR 20.103(b)(2).
The licensee's Health Physics Procedure H.P. 8.4 titled "Whole body
Counting Program" in Section 5.2.1 under the heading "Exit Whole body
Counting" states, "All personnel, whether permanent or temporary,
will be whole body counted at the time of their film badge termination
unless the Plant Health Physicist deems a count not necessary based
on the work performed and the area it was performed in by the indivi-
dual."
One individual working with the CPC Travel Crew was identified
as having worked at Palisades in the last half of September and early
October 1979.
The worker was terminated following work on October 8,
1979, and was not given a whole body count although he had worked in
containment including the steam generator.
Further, the Health
10/
IE Inspection Report No. 50-255/79-06
- 7 -
..
Physicist had not deemed a whole body count unnecessary.
Failure
to conduct a whole body count on this individual upon termination
constitutes noncompliance with Technical Specifications 6.8.1 and
6.11.1, which require that radiation protection procedures be im-
plemented and adhered to.
Licensee personnel indicated a general problem exists with the rad-
iation protection department not being made aware, for the purpose
of obtaining whole body counts, when contractor workers and even
CPC travel crew workers are terminated.
One item of noncompliance was identified involving failure to conduct
a procedurally required whole body count of an individual upon his
termination of employment.
9.
The inspector reviewed the licensee's efforts to maintain exposures
as low as reasonably achievable.
As noted in Paragraph 3 an ALARA
Committee has been established and has had three meetings, including
the initial meeting on June 13, 1979.
Supervisory personnel from
Radiation Protection, Operations, Mechanical Maintenance, Electrical
Maintenance or I and C, and Plant Engineering are represented on the
Committee.
Procedures were observed to address ALARA.
Efforts in this area include the following:
a.
Modifications have been completed which provide
access control for better control over movement
and equipment to and from the controlled area.
,.
more room at
of personnel
b.
Mock-ups were assembled and used in training for steam genera-
tor work and for control rod drive coupling and uncoupling.
Even though it worked well in the mock-up, three attempts were
required before the coffer dams were installed in the steam
generator legs without leakage.
Steam generator work progres-
sed smoothly after that.
c.
Fuel moving activities were conducted smoothly due to a success-
ful rework of the refueling machine before the outage.
d.
Deconning efforts were significanly increased.
The first 24
hours in containment during the outage were spent deconning.
Further, during the outage, a contractor labor crew was utilized
each shift for some routine and non-routine deconn~ng efforts.
The licensee uses a criterion of 25,000 dpm/100 cm
as the limit
of removable contamination above which use of respiratory pro-
tective equipment is required.
e.
Two portable dry cleaning units were utilized during the outage
for cleaning protective clothing.
- 8 -
f.
A TV camera provided remote monitoring of work in the steam
generator area to aid in reduction of exposure of personnel .
Consideration is being given to expanding this capability in
the future.
Other areas have been identified by the ALARA Committee to evaluate
for feasibility in reduction of personal exposure.
No items of noncompliance or deviations were identified.
10.
Posting and Control
During inspection of the licensee's facilities, the inspectors ex-
amined radiation caution sign postings, high radiation area access
controls, radiation work permit usage, and survey postings for con-
formance to regulatory requirements a~q
1
the licensee's procedures.
At the time of a previous inspection ~ several problems had been
identified with the licensee's high radiation area access controls.
The licensee's corrective measures appear adequate and are briefly
described in Paragraph 3.
During a plant tour the HRA's were found
to be properly posted and controlled.
One locked door recently was
found not locked in that it was not quite closed.
The locks auto-
matically activate if the door is fully closed.
The door in question
has to be pulled snugly to close.
The licensee stated that this
matter is being reviewed and may require some minor modification to
the door.
No problems were identified with other posting and controls, includ-
ing:
RWP controls; posting of radiation areas and contaminated
areas; and posting of documents required pursuant to 10 CFR 19.11
No items of noncompliance or deviations were identified.
11.
Radioactive and Contaminated Material Control
The inspector reviewed the licensee's methods of controlling radio-
active and contaminated materials during this outage.
No problems
were observed as a result of this review or as a result of observa-
tions during plant tours. (Refer to Paragraph 17 regarding a problem
with radioactive material control before the current refueling outage.)
12.
Surveys
Radiation, contamination, and airborne survey records associated with
the outage for the period of September 10 through October 31, 1979,
were reviewed.
Airborne activity concentrations, in general, were
.!..!/
IE Inspection Report No. 50-255/79-06
- 9 -
low.
LOE
58.
were
The highest concentration observed in review of records was
08 ;iCi/cc.
The activity was identified as principally cobalt
In general, when elevated levels of contamination or radiation
identified, the follow-up action appeared proper and timely.
Refer to Paragraph 3 for additional information regarding actions
taken in response to a previous item of noncompliance involving
radiation and contamination surveys.
No items of noncompliance or deviations were identified.
13.
Licensee actions regarding radiation levels in areas adjacent to the
~uel el~men12 7ransfer tube w7re partially re~iewed ~uring a prr~f ous
inspection ~* and as noted in a subsequent inspection report ~
the licensee planned to measure radiation levels in several areas
while transferring fuel during the next refueling outage.
Measure-
ments were made on October 2, 1979, by placing TLD badges at selected
locations (considered to have highest potential for multiple scatter
radiation field increase due to fuel transfer) outside containment
and inside containment (four) while two spent fuel bundles passed
through the transfer tube from the reactor to the spent fuel pool.
The exposure measured by the TLD badges outside containment ranged
from 11 to 15 mR during the six hour period which the two bundles
passed through the transfer tube.
Inside containment exposure
ranged from 47 to 345 mR.
Background radiation contributed signi-
ficantly to the highest exposure, due to location of the TLD near
primary coolant pump.
It was concluded that the fuel transfer tube
shielding effectively precludes any appreciable hazard.
No items of noncompliance or deviations were identified.
14.
This information notice deals with the interconnection of contam-
inated systems with service air systems used as a source of breathing
air.
The licensee has not completed action on this matter.
A plant
memo identified as "Palisades Plant Air A-PN-79-14," prepared by the
plant health physicist, indentifies the interconnections of contam-
inated or potentially contaminated systems with the service air system
used as breathing air and identifies the current means of providing
separation to preclude contamination of the breathing air.
The
evaluation of the adequacy of the system as it currently exists has
not been completed.
Final review of this matter will be completed
during a future inspection.
12/
IE Inspection Report No. 50-255/78-21
13/
IE Inspection Report No. 50-255/79-06
- 10 -
15 .
'
Audits
During a previous inspection 14/ in the area of audits, the licensee
agreed to review Procedure H.P. 2.3, "Investigation of Radiation
Protection Related Procedural Discrepancies," regarding the need for
a numbering system for identification of reports; a means to ensure
timely evaluation and follow-up where needed, and a definition of the
type of occurrences to be included in the report system.
The licensee
reviewed this matter and decided to replace this system with another
existing plant system, the "Deviation Report" system, as this system
already provides for the listed areas of concern.
No items of noncompliance or deviations were identified.
16.
Instruments and Equipments
At the time of a previous inspection 151, continuing problems were
noted with operability of portable continuous air monitors (CAMs)
and with operability of an automatic sample changer (ASC).
Also,
the continuing problem was noted of four radiation area monitors
(RAMs) having insufficient internal check sources for the containment
background radiation levels in which the monitors are located.
The
inspector determined the status of these rather long-standing problems
which the licensee had agreed to resolve.
Since completion of modifications to the ASC about six months ago,
the unit has functioned without significant problems.
The licensee had two of the three CAMs operational for the outage;
one in containment and the other at the Fuel Pool area.
Parts were
on order for the third unit.
The licensee had obtained a supply of
the more frequently needed spare parts to minimize instrument down
time.
Regarding the RAMs units with insufficient check sources, the
matter has been carried in the Deviation Report system since late
1978.
The instrument manufacturer has been contracted to design,
manufacture, and provide new check source assemblies with movable
shields.
These were initially scheduled by the manufacturer for
completion by August 1, 1979.
The manufacturer then informed the
licensee that completion would be delayed to January 1980, due to
"problems". In a more recent contact, the manufacturer stated June
1980 would be the delivery date.
This matter was discussed at the
exit interview.
14/
IE Inspection Report No. 50-255/79-06
15/
IE Inspection Report No. 50-255/79-06
- 11 -
17.
Secondary System Demineralizer Resin
As noted in a previous report 16/ powdered resins (Powdex) are used
in the condensate demineralizer system (secondary system).
Some
initial testing of the condensate demineralizer system took place
in April 1978, with further pre-op testing commencing in mid-October
1978.
These tests or use took place tµrough late December 1978.
In March 1979, some resin (used in the fall of 1978) was emptied
from the system.
The demineralizer system was again used starting
in early June 1979.
On June 8, 1979, some of this resin was removed from the phase
separator tanks and tested for radioactivity before disposal.
Low-level activity was detected for the first time.
A check was
then made of a Dumpster containing eight or nine barrels of resin,
six of which were "old" resin from the autumn run, but recently put
in the Dumpster.
Trace activity was found in the Dumpster, the
surrounding area, and on the beach.
The Dumpster was not sealed at
the bottom.
Heavy rains on June 7 and 8 had resulted in some resin
which came out of the Dumpster being carried to the beach via a
storm sewer.
The Dumpster was moved inside and clean-up promptly
undertaken.
The clean-up included use of earth moving machines on
the beach area.
NRC and State officials were notified.
A state
representative obtained sand and lake samples on June 10, 1979.
The licensee's analyses indicated that probably less than two cubic
feet of resin containing less than 19 microcuries of activity
reached Lake Michigan.
The sand and resin recovered in the clean-up was handled as radwaste.
Also, the resin still on site in early June 1979, and all future
resin from the condensate dernineralizer system, are being handled as
radwaste and shipped to a licensed radwaste burial facility.
Surveys
on June 8, 1979, of the Feed Water Purity Building (location of the
condensate demineralizer syste) showed a maximum reading of 0.2 mR/hr
on the bottom of a phase separator.
The area was then properly
posted as a radioactive material area.
Contamination surveys showed
nothing above 200 dpm/100crn2 .
The licensee's study of operating history showed that up to 1097
cubic feet (62 batches) of Powdex resin may have been disposed off-
site at a local landfill and that about 248 cubic feet (14 batches)
were still on site at the time the detectable activity was first
discovered on June 8, 1979.
Before June 8, 1979, apparently no
samples from batches that had potential for radioactivity had been
analyzed for radioactivity.
Records of surveys believed by the
licensee to have been conducted as general practice for materials
16/
IE Inspection Report No. 50-255/79-16
- 12 -
taken offsite were not maintained.
Of the 1097 cubic feet of Powdex
resin sent to a landfill, 17 batches or about 300 cubic feet had no
service hours or use, or was used for hotwell recirculation and,
therefore, probably contained no detectable activity .
The licen-
see's calculations, based on subsequent analyses of limited old
samples, service hours, and reactor power level, indicate that the
Powdex resin sent to a landfill may have initially contained about
13 mCi of activity.
By mid-June when the evaluation was conducted,
this activity would have decayed to about 6mCi consisting of about
58% cobalt 60, 28% manganese 54, with the remainder consisting of
cesium 134, cobalt 58, and cesium 137, in that order.
Licensee
evaluation shows that the highest activity was associated with the
159 cubic feet disposed of on December 12, 1978.
The concentration
of combined activity on the Powdex resin at that time was about
1.3E-3 J1Ci/g.
This activity would have decayed to a concentration
of about 6.2E-4...uCi/g by mid-June 1979.
For purposes of comparison,
the cobalt 60 concentration was evaluated by the licensee to be
about 2.9E-04...uCi/g in December 1978 or a total of about 1.8 mCi in
the 159 cubic feet buried in the landfill.
10 CFR 20.304(a) limits
the amount of cobalt 60 that may be buried at any one location and
time to 1 mCi.
Therefore, the licensee apparently failed to make a
proper evaluation for the presence of radioactive material in refuse
before releasing the refuse to a landfill for burial.
This consti-
tutes apparent noncompliance with 10 CFR 20.201(b).
For purposes of comparison, in December 1978 the concention of
activity on the Powdex (per gram) was about 23 times the MPC for
water (per gram) permitted for release to an unrestricted area (10
CFR Part 20, Appendix B, Table II, 'Column 2).
By mid-June this
concentration had reduced to about 15 times MPC, due to .radioactive
decay.
The powdex resin was buried in the lower of two layers of waste
material at the landfill and hence was apparently in a layer between
5 and 10 feet below the surface.
Attempts to locate the material
by use of sensitive instruments on the surface were not successful.
The licensee believes this indicates that the actual activity in the
landfill may be lower than that previously estimated by calculation.
During August 13-17, 1979, numerous core samples were taken from a
Covert Township landfill site in two or three areas considered to be
the most likely locations of the buried Powdex resins.
Analyses of
these landfill samples failed to identify radioactivity of nuclear
plant origin.
Concentrations of activity in the samples were below
the minimum level of .detection (1.0E-07 J1Ci/g) for nuclides such as
cobalt 58, cobalt 60, and manganese 54, which might be expected to
be present in the Powdex.
Additional efforts were made the week of
October 1, 1979,to locate the Powdex in the landfill by use of a
backhoe.
Five trenches were dug to a depth of 8-10 feet in locations
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the landfill operator identified as potential burial areas during
the period April through December 1978, when material was being
hauled from the Palisades site.
Samples were obtained from the
excavated material and an Eberline micro-R/hr survey instrument
utilizing a scintillation probe was used to scan the trench walls
and floor.
No identifiable quantities of Powdex were found and
no abnormal radiation levels were detected except for some origina-
ting from some discarded fire brick, not from the Palisades plant.
As the backhoe work in the week of October 1 was insufficient to
complete the sampling planned for this method, additional backhoe
sampling was conducted in November 1979.
Again, no identifiable
quantities of Powdex resin were found.
The licensee has no plans
at this time to make further effort at locating the Powdex resin.
18.
The licensee addressed IE Bulletin No.79-19, "Packaging of Low-Level
Radioactive Waste for Transport and Burial," in a letter to the
Commission on September 25, 1979.
A review of the nine specific
items addressed by the bulletin showed that:
A.
Current sets of DOT and NRC regulations are maintained at the
site by the licensee.
Vendor services are utilized to provide
two updated copies of both DOT and NRC regulations.
B.
Current copies of licenses issued to burial firm licensees by
the agreement States of Nevada, South Carolina, and Washington
are maintained at the site by the licensee.
C.
Attachment A to Section Two of the Plant Adminstrative Proce-
dures designates the Radiation Materials Control Supervisor as
being responsible for the safe transfer, packaging, and tran-
sport of low-level radioactive material.
D.
(1). Since August 1979, The Radiation Protection Group provides
direct health physics coverage for all packaging of rad-
waste.
Procedures H.P. 2.44 "Low-Level Waste Packaging"
and H.P. 6.20 "Radioactive Waste Shipment" provide de-
tailed procedures for the transfer, packaging, and tran-
sport of low-level radioactive material.
These procedures
are approved by the Plant Review Committe (PRC) and the
General Manager.
(2). The procedures prohibit shipment of liquid for radwaste
burial.
Further, absorbent material is required by pro-
cedure to be placed in the bottom of each package of
compactable and non-compactable trash.
A test was per-
formed by the licensee at the General Office with clean
bead-type resins, using a pump and both a well point type
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l
and a Chem Nuclear "spider" dewatering device.
Test re-
sults showed the spider-type dewatering device to result
in no "free-standing" water.
Initial results were not
successful with the well point device.
The spider-type
mechanism is the only dewatering device authorized by the
licensee at this time for the bead-type resins.
(3). The use of urea formaldehyde to solidify evaporator bot-
toms has been discontinued and a silicate cement solid-
ification process is being used in the interim until an
asphalt solidification system is installed in about two
years.
The procedure for the silicate cement process
which is prepared and in test usage, involves removal of
a drain plug at intervals following the curing process to
ensure that no free standing water is present.
Small
amounts of liquid, on the order of a quarter of a pint,
were drainable from some of the initial 50 cubic foot
liners.
None of these liners had been shipped or con-
sidered ready for shipment as of the inspection date.
(4). A container checksheet, H.P. 2.44-1, is attached to each
container and is to stay with the container from the time
of initial loading through shipment.
This checksheet,
which has to be signed off as being complete before
shipment, verifies that absorbent material was used; that
the container was checked for absence of liquid; that
material contents are properly identified; that the closure
is properly in place; and that proper marking, labeling,
and surveys have been performed.
Some minor discrepancies
and a few changes needed for clarification were identified
by the inspector in Procedures H.P 2.44 and H.P 6.20.
E.
The Radiation Protection Group, which provides direct health
physics coverage for all packaging, received training on the
dates and subject areas listed below:
November 2, 1978 -
DOT Regulations
February 28, 1979 - Procedure H.P. 6.20, Cask Certification
of Compliance and Licenses Issued to
Burial Facilities
March 14, 1979 -
April 12, 1979 -
October 26 and
October 28, 1979
10 CFR 30 and Licensee's Operating
License, DPR-20
10 CFR 40 and 71, and Compactable
Trash Handling
Procedure H.P. 2.44
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,
'
Periodic retraining is planned during the four-hour, weekly training
sessions provided, except during outages .
F.
Fifth shift training is planned to provide operators by
January 15, 1980, with training to minimize volume of waste
generated and to process the waste into acceptable chemical
and physical form for transfer, shipment, and burial.
Per-
iodic retraining of operators is to be covered in the fifth
shift training.
G.
To aid in an audit program of activities associated with the
transfer, packaging, and transport of low-level radioactive
waste, the licensee utilizes the following:
(1).
(2).
(3).
Direct health physics coverage of all packaging of trash
and completion of a Container Checksheet, H.P. 2.44-1,
covering the filling of container and loading it onto a
truck, assuring absence of liquid, assuring proper closure
and labeling, and assuring required surveys have been per-
formed.
Quality Assurance Checkoff Sheet for Casks, signed and
dated by both the H.P. Technician and the H.P. Supervisor,
certifying that information on the form is correct, and
that the cask has been loaded and tested in accordance
with approved procedures, and that all appropriate condi-
tions of the certificate of compliance have been met.
This sheet identifies cask model and serial number, shipper,
and driver, and confirms that the cask certificate of com-
pliance and user certificate are both on file.
This check-
off sheet also covers subjects such as gaskets and seals,
lid bolt torqueing, tiedowns, surveys, and placarding.
The Radioactive Material Shipment Record (RMSR) is signed
by the Radioactive Material Control (RMC) Supervisor cert-
ifying that the materials are properly classified, described,
packaged, marked, and labeled, and are in proper condition
for transportation.
The RMSR indentifies the licensed
receiver, his license number, and its expiration date. It
also identifies the physical form of material, DOT quantity,
transport group, quality assurance checklist completion
verification, principal radionuclides, curie content, con-
tainer description, volume, approximate weight, cask type
and serial number, number of packages, survey date of
container and vehicle, labeling and placarding compliance,
and State Police notification.
(4). In addition, effective October 23, 1979, the plant QA
Superintendent or his designate must review each shipment
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documentation package for adequacy before release of the
shipment.
Completion of the QA review is documented on
the RMSR form.
This function may be transferred to the
Q.C. group.
(5). The Q.A. group conducts periodic surveillance or m1n1-
audits and has reports of findings and observations as
well as provisions for subsequent follow-up.
Two such
audit reports were reviewed:
QP 79-27 regarding surveil-
lance conducted October 19-24, 1979, of packaging documen-
tation and movement of compactable and non-compactable
radwaste (Procedure H.P. 2.44); QP 79-28 regarding sur-
veillance conducted November 4-6, 1979, of packaging and
shipment of LSA radwaste (Procedure H.P. 6.20).
A third
mini-audit is planned for the cement solidification process.
The minor problems identified by the audits had been cor-
rected or were being followed by QA auditors.
H.
A management controlled audit of activities associated with
the transfer, packaging, and transport of low-level radio-
active waste was performed during a portion of the Technical
Audit conducted August 13-23, 1979, under the leadership of
corporate management personnel.
No deviations "significant to
safety" were identified by the audit.
I.
The licensee submitted to the NRC a written plan of action
(dated September 25, 1979) and schedule with regard to the
items listed in the bulletin.
The licensee does generate
liquid low-level waste.
Solidification of this waste with
the urea formaldehyde (UF) system has been recently discon-
tinued in favor of a cement solidification process.
In about
two years, an asphalt solidification system is planned to
replace the cement system.
Answers to other questions in the bulletin regarding radwaste
ship ments are covered in semiannual reports made to the
Commission in accordance with Technical Specification require-
ments.
No items of noncompliance or deviations were identified
regarding packaging low-level radioactive waste for transport
and burial
19.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph
1) at the conclusion of the inspection on November 16, 1979.
The
inspector also had a discussion by telephone with the plant Manager
on January 28, 1980.
The inspector summarized the scope and findings
of the inspection.
In response to certain items discussed by the
inspector, the licensee:
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a.
Acknowledged the inspector's comments regarding progress noted
in resolution of the operability problems with the CAMS, ASC,
and RAM check sources.
The licensee agreed to contact the de-
signer/manufacturer of the check sources in the interest of
shortening their delays in delivery of the new source assemb-
lies.
(Paragraph 16)
b.
Acknowledged the three apparent items of noncompliance, two of
which occurred during this refueling outage and the third before
the outage.
(Paragraphs 7, 8, and 17)
c.
Acknowledged incompletion of the evaluation regarding adequacy
of the current means of separation of contaminated systems with
the service air system used as a source of breathing air (IE
The licensee agreed to complete
this evaluation.
(Paragraph 14)
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