ML18052B243
| ML18052B243 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/19/1987 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8708210651 | |
| Download: ML18052B243 (5) | |
Text
Kenneth W Berry Director*
Nuclear licensing General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 August 19, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IE INSPECTION REPORT 87-005 NRC Inspection Report 87-005 dated July 20, 1987 transmitted one violation which requires a response by August 19, 1987.
The cover letter to the Inspection Report also requested that we include in our reply actions taken or planned to improve the effectiveness of controls over high radiation areas greater than 1 R/hr, including measures to strengthen radiation protection job coverage.
The following is our response to the violation and additional cover letter concerns:
Violation (255/87005-0l(DPR)'
10CFR Part 50, Appendix B, Criterion V, requires "activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings." Palisades Administrative Procedure No 9.23, Revision 5, Section 6.3 states, in part, that while per"":"
forming a surveillance, if a mistake is made, it shall be crossed through, initialed, dated and the correct data recorded.
Contrary to the above, Surveillance Test Procedures RI-04 performed on February 28, 1987; RI-OS-performed on January 23, 1987; and SH0-1 performed on April 17, 1987 had data errors that were not crossed through, initialed and dated.
Instead, the data in error on RI-04 and RI-05 had been "whited-out" and written over with new data and in the case of SH0-1, the data in error had been erased and then written over.
Corrective Actions Taken and Results Achieved During the performance of RI-04, "Steam Generator Level Channels Calibration" on February 28, 1987, and RI-05, "Steam Generator Pressure Channels Calib-ration" on January 23, 1987, a senior Instrument and Control engineer utilized.
"white-out" while performing an evaluation of instrument performance.
In this evaluation, the as-found test data is compared to a unique zero shift. The evaluation was performed in the remarks section of an Instrument Calibration and Setpoint Verification Form.
This form is an attachment to Plant Admin-istrative Procedure 5.04, "Control of Installed Plant Instrumentation" and is l(~o\\
~,,o IC0887-0143A-NL02 8708210651 870819 PDR ADOCK 05000255 Q
r Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-005 August 19, 1987 used extensively to determine instrument performance during the calibration interval.
The remarks section of the Setpoint Verification Form is not utilized as the formal data recording medium during these surveillance tests, nor is it a formal portion of the surveillance test, so that under no circumstances was original test data altered.
2 While recording test data during the performance of SH0-1, "Operators' Shi~t Items", original test_ data was recorded in ink, erased and another valve*
recorded.
The test data that was erased had been inadvertently recorded in the wrong location.
When the error was noticed, the operator erased the entered data and recorded it in its proper location.
When the erasures were pointed out by an NRC inspector, the entered data was validated and initialed by the operator and Shift Engineer as intentional. _All individuals involved with the events described above have been counseled and made aware of the procedural requirements to cross through, initial, date and record the correct data when an error has been made.
Corrective Actions To Be Taken To Avoid Further Non-Compliance The procedural requirements for data recording and evaluation during the performance of Technical Specification Surveillance Procedures will be relayed to Plant Operations personnel via their continuing training program.
This information will be placed in the industry experience module for training prior to the end of August 1987.
Procedural requirements are being reiterated to Plant Engineering personnel via memo drafted by the System Engineering Superintendent.
This memo will be routed to applicable personnel through their continuing training program to assure all required personnel have received the information.
Date When Full Compliance Will Be Achieved Operations Department continuing training will begin by the end of August and will be completed by the end of October 1987.
Engineering personnel will have reviewed the procedural requirements prior to October 1987.
Response To NRC Request For Additional Information Within IE Inspection Report 87005, NRC inspectors identified certain activities which raised concern about potential programmatic weaknesses with Health Physics controls in high radiation areas (greater than 1 R/hr).
Consequently, Consumers Power was requested to describe those actions taken or planned to improve the effectiveness of controls over high radiation areas of greater than 1 R/hr, including measures to strengthen radiation protection job coverage.
IC0887-0143A-NL02
Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-005 August 19, 1987 Ingress/Egress Control Of High Radiation Areas Of Greater Than 1 R/hr 3
An NRC inspector cited three events resulting in procedural, 10CFR20 and/or Plant Technical Specification violations regarding high radiation (greater than 1 R/hr) entry/exit controls. Detailed below are actions taken or planned regarding positive Health Physics control for high radiation areas of greater than 1 R/hr.
Since two of the three instances discussed in IE Inspection Report 87005 occurred* in the West Safeguards Room, this work area received special consideration.
The exit hatch (emergency hatch) in the ceiling above was modified to allow immediate exit while stili preventing entry into the room from above to the West Safeguards Room.
The area was posted to alert workmen to the emergency means of escape.
In addition, a telephone has been installed in this room.
An engineering evaluation is in progress to reduce dose rates to less than 1 R/hr so that the external lock on the watertight door leading to the West Safeguards Room may be removed.
The engineering evaluation should be completed by November 1987.
The 1 R/hr door leading to the Dirty Waste Drain Tank Room (T-60) contains a
- built-in door lock that requires personnel to push in a button on the core lock in order to lock the door upon exiting.
Although signs above the lock on both sides of the door require the exiting person to push the button.in to lock the door, it was felt the administrative control was less than adequate.
The 1 R/hr door lock core and door handle were replaced on August 10, 1987, thus deleting the requirement and use of the lock button.
Signs ~hove the*
door lock were removed.
The 1 R/hr door leading to the fuel pool heat exchanger contains a built-in
- lock that requires a key to be used in order to lock the door upon exiting.
This core lock was replaced and will lock upon door closure, thus deleting the requirement and use of a key to lock the door.
The Volume Control Tank ~oom (T-54) and Spent Resin Storage Tank Room (T-69) contain screen, see-through 1 R/hr doors with external locks.
An Engineering Support Request has been initiated to review the feasibility of modifying or replacing the screen doors with internal door locks necessitating key entry, but allowing access from the area.-
This review is expected to-be completed by October 1, 1987.
In addition, all 1 R/hr doors that require two-man entries, one of whom shall be a Health Physics Technician, will have unique core locks and a key iden-tifier for additional administrative controls
- Strengthening Radiation Protection Job Coverage The inspector identified an apparent discrepancy between "dedicated" radiation*
protection coverage defined in Palisades Administrative Procedure 7.03, IC0887-0143A-NL02
Nuclear Regulatory Commission Palisades Plant Response to IEiR 87-005 August 19, 1987 4
"Radiation Work Permit" (RWP) and periodic coverage for high radiation areas as required by Palisades Technical Specification 6.12.1.
Also, the inspector noted that no formal documented policy nor limitation on the number of jobs a Radiation Protection Technician (RPT) can provide dedicated coverage for simultaneously exists.
This issue was discussed by the Health Physics Superintendent in a memo dated September *12, 1986 to all Radiol_ogical Services personnel.
In this memo, "dedicated coverage technician" was defined as the technician assigned to the job being solely responsible for the radiological aspects of the work being performed.
This does not mean the workman needs to be in line of sight at all times, as in some cases it is not ALARA to do so.
However, the technician is responsible for providing positive control over the activities within the area.
All RWP's contain check boxes for, "dedicated", "periodic", "initial survey only" and "see special instructions". It is not unusual to check on the RWP boxes for "dedicated"," periodic" and "see special instructions".
The comment section of the RWP will have notes which apply to each box marked.
For instance, a note for dedicated coverage may indicate, "during system breach",
or "during pump head removal".
A note for periodic coverage may state, "after system breach" or "after pump removal".
These definitions and use are clearly
- understood by all technicians. However, definitions in Administrative Procedure 7.03, regarding the term periodic, are unclear.
Appropriate Adminis-trative procedures will be revised by November 1, 1987.
It is current practice to assign a dedicated coverage technician to two or more jobs depending on the radiological conditions in the work area, and type of work to be performed~* *The number of jobs covered simultaneously depend upon several factors including, presently existing radiological conditions; the potential for change in the radiological environment during the job, and the proximity of the jobs with respect to the RPT.
These factors are given consideration by the Duty Health Physicist, lead technician and the technician in the* field before making job assignments.
The September 12, 1986 memo to all Radiological Services personnel discussed this practice and directed RPT's to stop-any job when they feel positive control cannot be maintained.
Therefore, we feel the memo discussed above serves as the policy on this matter. and clarifies both what constitutes dedicated coverage and our position on multi-j.ob coverage by a single RPT.
In addition, the memo clearly states the responsibility and authority for "stop work" situations.
This memo will be revised for inclusion in the Radiological Services Department Polic~es and Practices Manual and will be completed by October 15, 1987.
The issues presented by the inspector in IE Inspection Report 87005 were discussed with Radiolog*ical Services Department personnel in a July 30, 1987 continuing training session.
These issues will be presented to Operations personnel during their normal fifth shift continuing training program.
To further strengthen job coverage performance, a training course is being developed which will include discussions on industry experience, expectations IC0887-0143A-NL02
Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-005 August 19, 1987 5
during job coverage and provide for workshops of job coverage situations.
The course is expected to begin approximately by the end of October 1987.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRG Resident* Inspector - Palisades IC0887-01°43A-NL02