ML18057A523
| ML18057A523 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/05/1990 |
| From: | Grant W, Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A521 | List: |
| References | |
| 50-255-90-19, NUDOCS 9010160290 | |
| Download: ML18057A523 (19) | |
See also: IR 05000255/1990019
Text
U.S. NUCLEAR REGULATORY COMMISSION
Report No. 50-255/90019(DRSS)
Docket No. 50-255
- * REGION I I I
Licensee:
Consumers Power Company
1945 West Pa~nall Road
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, Michigan
License No. DPR-20
Inspection Conducted:
August
Inspector:
w~:~;!:!-/,,..._
13-17, September 10-14, and September 19, 1990
- w.~~
A. W. Markle1~
w.SJI
Approved By:
W. Snell, Chief
Radiological Controls and
Emergency Preparedness Section
Inspection Summary
\\O/S /Jo
Date
10/S-bo *
Date*
Date
Insp~ction on August 13-17, Se tember 10-14, and Se tember 19, 1990
Re ott No. 50-255/90019 DRSS
Areas Inspected:
Routine unannounced inspection of the.~adiation protection,
radwaste and transportation programs, including: organization, management
controls and training, audits and appraisals, external exposure control,
internal exposure control, control of radioactive materials, contamination,
and surveys, and maintaining occupational exposures ALARA (IP 83750, 84750).
The inspection also included:
gaseous radwaste, liquid radwaste, solid waste
and transportation, effluent reports, effluent control instrumentation,
primary coolant chemistry and air cleaning systems (IP 83750, 84750).
Reviewed open items from pa~~ identified concerns (92701).
Results:
During this inspection, apparent willful violations associated
with a failure to provide the required practical factor portion of General
Employee Training and a subsequent falsification of training records to
indicate that the required training was performed were identified (Section
4). Also, two apparent violations (one potentially willful) of high
radiation area access control requirements were identified (Section 6).
A non-cited violation was identified in the area of Semiannual Effluent
Release _reporting (Section 13).
9010160290 901005
ADOCK 05000255
Q
PNU
Programmatic weaknesses were identified in the area of quality assurance
surveillances (Section 5) and in the material condition of the boric acid
pump/storage tank room (Section 18).
Programmatic strengths were identified
in the following areas:
licensee response to a fire (Section 19); house-
keeping and material conditions (with exceptions) (Section 18); instrument
use and calibration (Section 18); mockup training facilities and
implementation (Section 4); reductions in gaseous effluents (Section 9);
and licensee responsiveness to apparent willful violations (Section 4 & 6).
2
DETAILS
1.
Persons Contacted
- C. Axtell, Health Physics Consultant
- E. Bogue, ALARA Coordinator
- @K. Haas, Radiological Services Ma~ager
- J. Hadl, Senior Quality Assurance Consultant
- L. Kenaga, Health Physics Superintendent
-
@D. Joos, Vice President
- M. Lesinski, SGRP Radiation Protection Manager
- J. Lewi~, SGRP Engineering
- K. Marbaugh, SGRP Quality Assurance Superintendent
- R. Mcca*leb, Quality Assurance Director
M. Mennucci,
Se~ior Health Physicist
- T. Neal, R~dioactive Material Coordinator
R. Orosz, Engineering and Maintenance Manager
- J. Petro, Section Head Quality Engineering
- W. Roberts, Licensing Staff Engineer
- R. Poche, Licensing
- P. Rigozzi, Training Supervisor
- D .. Rogers, Training Administrator
- J. Schepers, Quality Assurance
- G. Slade, Plant General Manager
- M. *Snigowski, SGRP Administrative Controls Manager
- @D. VandeWalle, Safety ind Licensing Director *
- J. Werner, SGRP Quality Assurance
J. Heller, Acting Senior Resident. Inspector
- E. Schweibinz, Project ~nspector
The inspectors also interviewed other Licensee and contractor
personnel during the course of the inspection.
- Denotes those present at the interim exit meeting on August 17,
1990
- Denotes those present at the exit meeting on September 14, 1990.
@ Denotes those contacted by telephone on September 19, 1990.
2.
General
This inspection was conducted to review aspects of the licensee's
radiation protection radwaste/radioactive material shipping and
transportation programs.
The plant's readiness to support the Steam
Generator Replacement Project (SGRP) in the areas of radiation
protection and radioactive material control was evaluated.
Included
in this inspection was a follow-up of outstanding items in the areas
of radiation protection and radioactive waste management.
The
inspection included tours of radiation controlled areas, the auxiliary
building, radwaste facilities, observations of licensee activities,
3
3.
review of representative records and discussions with licensee
personnel.
Licensee Action on Previous Inspection Findings (IP 92701)
(Closed) Open Item No. 255/89025-01:
The licensee committed to
decontaminate the South Radwaste Building (SRB) to acceptable levels.
The licensee has completed the decontamination of the SRB and has
released the facility for non-radiological storage.
The inspectors
reviewed the final survey records; no problems were noted.
This item
is closed.
(Closed) Open Item No. 255/89025-04:
The licensee performed an
engineering evaluation to determine whether offsi~e dose savings
could be realized by treating containment depressurization/vents as
batch releases instead of continuous releases.
The licensee has
determined that the performance of containment releases as batch
releases would require extensive modifications to the plant and plant
procedures.
The cost to reduce the alread~ small quantities of
gaseous effluents released by continuous venting of the containment
cannot be justified by calculated offsite dose savings.
The offsite
dose to the public from all gaseous effluents released is generally
less than 0.1 person-rem per year.
Therefore, the modifications would
be uneconomical from a dose savings standpoint.
This item is closed.
(Closed) Unresolved Item No. 255/89025-10:
Evaluate the methyl
iodide charcoal adsorber testing program for adequacy of tests,
testing equipment and methodology.
The licensee has completed their
evaluation and the current testing methodology meets NRC regulatory
guidance.
Purchase Order CP 14-0139-Q has been revised to require
that the vendor test the carbon adsorbers in accordance with the
current ANSI test requirements (See Section 17).
This item is closed.
(Closed) Open Item No. 255/89025-11:
Evaluate the adequacy of the
op~rational requirements for containment air cleanup units.
The
licensee has completed their evaluation.
The charcoal adsorbers will
be tested during the current outage and if their efficiency is less
than 70 percent; they will be changed.
The units effectiveness in
reducing airborne iodine concentrations in containment will be
evaluated after the adsorbers have been shown to have an efficiency
of 70 percent.
This item is closed.
-
4.
Organizational, Management Controls and Training (IP 83750, 84750)
The inspectors reviewed the licensee's organization and management
controls for the radiation protection, radwaste, shipping and
transportation programs, including: organizational structure,
staffing, delineation of authority and management techniques used to
implement the program and experience concerning self identification
and correction of program implementation weaknesses .
4
a.
Organization and Management Controls
The __ r:-~di_a_t i or:i protectJon _and _radioactive waste management
organization remai,ns essentially the same as described in
Inspection Report No. 50-255/89030(DRSS).
The management staff
has remained stable with very low turnover.
A senior health
physicist who had served in signif{cant management positions
has retired and now serves as a consultant to the licensee .
. The li~ensee has augmented the radiation protection (RP) and
radioactive material control organizations with consul.tants and
contract radiation protection techhicians ~ho have specific
experience in steam generator replacement and recirculation
piping replacement projects.
The "normal" plant radiation
protection organization will be responsible for providing
radiological support for the refueling and maintenance portion
of the outage.
The SGRP radiation,p~otection group is a
parallel organization. It has its own radiation protection
manager, operations supervisors, ALARA group and technician
staff.
Lines of communication proceed l~terally to funct~onally
equivalent positions in the licensee's RP organization and
vertically within the SGRP RP organization.
Ultimat~ decision
making authority rests with the licensee's senior staff member
on shift.
To facilitate a cohesive work group, .the licensee engaged the
servic~s of a con~ultant to conduct team building ex~rcises.
Several sessions were held at various working l~vels: Team
building seminars were held with upper, middle and first line
management personnel from both the licensee's RP and the SGRP
RP organization. These sessions were designed to reduce fears
of loss of control, improve understanding and respect for
individual professional capabilities and integrate the
consultant and licensee staffs.
The SGRP organization has written and approved a SGRP Project
Plan.
This plan identifies project participants, scope of
work, responsibilities, qualifications and methodologies to be
implemented in.the conduct of the SGRP.
Appendix 5 of the
project plan contains the Project Radiological Plan.
This
document describes the duties, responsibilities, interfaces and
functions of the SGRP radiation protection organization. This
document received formal approval from the Plant General
-
Manager, Radiological Services Manager, SGRP Project Manager
and the SGRP Radiation Protection Manager.
b.
Training
The inspectors reviewed the training programs that were
established for the SGRP .. The lesson plans for contract RP
technician training were reviewed.
The lesson plans were
comprehensive and suitably target~d to the needs_ of the
contract radiation protection technicians.
The licensee
utilization of mockup training for significant SGRP activities
5
-
- -------
was excellent.
SGRP workers were trained in the performance of
large diameter pipe cuts, clad welding, narrow gap welding,
pipe end decontamination and containment wall cutting. With
the exception of the containment wall cutting, mockup training
was conducted on an actual steam generator bowl with attached
'cold and hot leg piping.
The containment wall cutting was
performed on an erected concrete semicircular wall that
contained steel reinforcing bars and support tendons.
This
concrete wall also had a steel liner plate on the inner side.
Radwaste Handlers receive General Employee Training (GET), basic
radiation protection, and basic radwaste handler training.
Advanced radwaste handler training is in its formative stages.
However,.the radwaste handlers are experienced and appear
proficient in their jobs.
c.
Apparent Training Records Falsification
On August 30, 1990, a contract training supervisor notified the
licensee's radiation protection training supervisor that he had
observed inconsistencies in General Employee Training (GET)
documentation.
The contract supervisor also reported that he
had obtained information from several contract radiation
protection (RP) technicians who had attended these classes that
indicated the practical factors portion of this training had
not been given.
In his report to the licensee's training
supervisor, the contract training sup~rvisor indicated that
neither he nor any of his instructors had observed performance
of practical factors in the classes in question.
The licensee commenced an investigation that included reviews
of pertinent documentation, interviews with the instructor in
question, interviews with all available contract RP technicians
(20 of 22) who attended the GET classes in question, and other
RP technicians who attended similar classes under this
instructor in the Spring of 1990.
In addition, eight RP
technicians were selected and interviewed regarding the
integrity and administration of pre-qualification and course
final exams.
Reviews of documentation indicated that the instructor in
question had signed off as having performed the lesson plan
that included the practical factor training (BRW-P-1).
This
instructor had also signed off that each technician had
performed the practical factors for both classes in question
(GET*151 and GET*157).
Documented on these practical factor
evaluation sheets was the instructor's evaluation, awarding of
demerits, and satisfactory or unsatisfactory determinations of
the trainee's performance of practical factors.
The practical
factors to be observed by the instructor included signing the
radiation work permit (RWP), reviewing the area status sheets,
testing the integrity of protective clothing, proper donning
and removing of protective clothing, proper use of dosimetry
- and computerized dose tracking, handling and removing of
radioactive materials from a contaminated area and student
6
response to questions regarding RWP requirements and informµtion.
Interviews with the contract RP technicians indicated that the
RP technicians had the differences explained to them regarding
dress out procedures*at Palisades versus techniques used at
other plants. However, not a single technician intervie~ed (20
interviewees) indicated that they had actually performed the
practical factors portion of the GET course.
Interviewee notes
made by the licensee also indicated that some of the RP
technicians indicated that they understood that they had been
"waived" from practical factor performance.
The licensee indicated to the inspector that plant management had
decided that although such waivers were pro~id~d for in plant
procedures, practical factor performance was not to be waived.
and the instructor in question knew this to be the policy.
No
documentation was presented by the licensee that documented
approval of waivers for performance of the practical factor
portion of the GET training.
The licensee indicated that the interviews conducted with trainees
associated with training provided by the instructor in question
also appeared to cast doubt as to whether the practical factors
portion of GET training was conducted during the Spring of 1990.
Interviews with the selected RP technicians indicated that the
examinations associated with the August 1990 training appeared to
be proctored acceptably.
During the conduct of testing, no one
was observed to have recaived answers to test questions from the
in~tructor in question.
Based on the information gathered, the licensee revoked radiation
control area (RCA) access for all RP technicians who were taught
by the instructor in question. Those RP technicians .who were still
employed on site-were required to perform the practical factor
portion of GET training before access to the RCA was restored.
Those RP technicians who were not on site had-their security badges
coded to deny access to the RCA.
In addition, a comment was placed
in the NUCPAS system for those personnel to contact the training
supervisor before their badge is reactivated. These actions were
also applied to those RP technicians who had received training
during Spring of 1990.
The certification to teach GET training
was revoked for the instructor in question. This instructor
has since terminated employment with the licensee.
d.
Apparent Regulatory Violations
Technical Specification 6.8.1 requires written procedures be
established; implemented and maintained.
General Employee and
Radiological Safety Training Program No. 1, Section 5.3.2 requires
that individuals who desire access to radiological areas must
complete Basic Radiation Worker Training*- Generic and Site
Specifics (N00403 & N00404).
7
Course N00404, Section 3.2 requires that the student demonstrate
proficiency in the following practical factors:* work under a RWP,
use of dosimetry, donning and removing protective clothing, entry
and exit of a contaminated area, and proper removal of an item
from a contaminated area. *
During the period August 20 through August 30, the licensee
determined that an instructor had willfully failed to provide the
required practical factor portion of General Employee Training
to twenty individuals who required access to radiologically
controlled areas. Eight of these individuals were subsequently
authorized access to the radiologically controlled area. This
is an apparent violation.
(No. 255/90019-01)
Procedure NT-013, section 4.2 states that the instructor shall:
instruct courses and administer examinations in accordance with
approved cl as~ schedules and lesson plans; be responsible for
the accuracy and completeness of the documentation in their
interim class file.
On August 20, 27 & 28, 1990, the licensee determined that the
instructor falsely had doc~mented that the ~ractical factors
portion of General Employee Training had been presented to two
GET classes and that the trainees had performed the required
practical factors successfully. This is an apparent violation.
(No. 255/90019-02)
Two apparent vio1ations were identified.
5.
Audits, Surveillances and Self Assessments (IP ~3750, 84750)
The inspectors reviewed the results of Quality Assurance audits and
surveillances conducted by the licensee since the last inspection. Also
reviewed were the extent and thoroughness of the audits and surveillances.
A separate SGRP.quality assurance organization has been established
to perform audits and surveillances of various SGRP activities. The
inspector reviewed the quality assurance reviews of the Project
Radiological Plan, project procedures and plant tour reports of
project activities.
No problems were noted.
The inspectors reviewed reports of QA audits for 1989 and 1990 to date.
The licensee's QA audit .program appears adequate to assess technical
performance, compliance with requirements, personnel training and
qualification ~elating to the radiation protection and radwaste waste
management programs.
The QA auditors assigned to review this functional
area appear to have the necessary expertise and qualifications.
Interviews with appropriate licensee personnel indicate that responses
to audit/surveillance findings are generally timely, and technically
sound.
,
Since the last inspection in November 1989, four surveillances were
conducted in the radiation protection and radioactive material control
areas. Three of these covered personnel contamination eyents and the
other covered temporary shielding. Other surveillances that were
8
~*
conducted in the mainfenance and plant oper~tions areas and plant tour
reports provided some feedback on operational radiation protection
activities such as RWP compliance, radiological postings, protec~ive
clothing and dosimetry usage.
However, the inspector expressed concern
that the licensee's quality assurance surveillance program had not
covered the ~ange of activities contained in the radiation protection
and-radioactive waste management programs.
The licensee was engaged in general review of the quality assurance.
program due to a previous NRC identified ~eakness irr the review of
emergency operating procedures.
Expansion of surveillance activities
in the area of concern had been identified by the 1 i censee.
The
implementation of the expanded quality assurance surveillance program
will be evaluated during a future inspection (Open Item 255/90019-03).
No violations or deviations were identified.
One open item was
identified.
6.
External Exposure Control (IP 83750):
The inspector reviewed the licensee's external exposure control and
personal dosimetry program, including: change:s in the program, use of
dosimetry to determine whether requirements were met, planning and
preparation for maintenance and refueling outage tasks including
ALARA considerations and required records, reports and notifications.
a.
Personnel Dosimetry Program
Personnel exposure fecords for.current arid past licensee and
contractor employees were selectively reviewed for completeness,
accuracy and inconsistencies.
In addition, reporting of exposure
information was reviewed for timeliness.
No problems were noted ..
- The licensee is in the process of changing their dosimetry system.
The current Teledyne system is National Voluntary Laboratory
Accreditation Program (NVLAP) accredited in five out of eight
areas (II, IV, V, VII, & VIII) by virtue of actual demonstration.
of compliance with ANSI N13.11 - 1983 through testing. The new
system is a Panasonic model that has received accreditation in all
eight areas of concern.
The licensee has implemented the use of a Merlin-Gerin electronic
dosimetry system.
This system of personnel exposure monitoring has
replaced the self reading pocket dosimeters.
This system has the
capability to alarm at predefined dose accumulation levels and .
at pr~defined dose rates.
The dose accumulation alarm will not
clear until the..dose has been recorded in the dosimetry system.
The dose rate alarm will clear when the individual leaves the area
that exceeds the predefined dose rate.
Prior to first use of the
electronic dosimetry, each individual is trained in its use.
This
includes watching a short film that discusses proper use, follow-up*
discussions and a walk through to observe actual check in and check
out procedures.
9
The inspector expressed a concern that the administrative exposure
control system did not facilitate minimization of individual
exposure.
The current system of exposure authorizations is
characterized by three exposure control levels:
250 mrem/qtr
(incomplete records with current quarter expo~ure), 1100 mrem/qtr
(incomplete re~ords without current quarter exposure) and 2500
mrem/qtr (complete exposure history). While this system is
augmented by alert levels of 850 mrem (for the 1100 mrem limit)
and 2000 mrem (for the 2500 mrem limit), an individual conceivably
could follow all the rules, stay within individual RWP exposure
limits and accumulate 2000 mrem of exposure without any additional
management review.
The licensee acknowledged the inspector's concern. and commenced an
evaluation of the existing system of exposure authorization.* By
the completion of the inspection, the licensee had developed a draft
work plan to implement a graduated system of exposute authori~ations.
This system would be characterized by authorizations at 1100 mrem,
1500 mrem, 2000 mrem and 2500 mrem on a quarterly basis. Each
subsequent level of approval would require increment~lly higher
management approvals .
. No-violations or deviations were identified.
b.
High Radiation Area Barrier Incidents
On August 13, 1990, the inspector made a tour of the licensee's
radiation controlled ~rea (RCA) with a licensee provided RP
technician. During this tour, a high radiation area in the NSSS
room was found with the radiation rope at the access point and the
high radiation area posting laying to the floor face down such that
it was not conspicuously apparent that this was the entrance to a
high radiation area. The area was surveyed and dose rates in
excess of 100 mrem/hour could not be found.
This area is known
to experiente fluctuating dose rates. The barrier was i~mediately
reestablished and posted as~ high radiation area.
During a subsequent tour of the RCA on September 11, 1990, two
inspectors found the same high radiation area in the NSSS room
with the radiation rope and the high radiation area posting .
laying on the floor behind a bag utilized to collect contaminated
trash.
The area was surveyed and dose rates in excess of 100
mrem/hour were found in the area. The licensee reposted and
- rebarricaded the area as a high radiation area.
The licensee
initiated a~ evaluation of their method of posting and barricading
high radiation areas to determine corrective actions to preclude
recurrence of this type of event. This action was initiated prior
to the conclusion of the inspection. This is a violation of
Technical Speciftcation 6.12.1 which requires that each high
radiation area in which the intensity of radiation is greater
than 100 mrem/hour but less than 1000 mrem/hour shall be
barricaded and conspicuously posted as a high radiation area.
(Violation 255/90019-04)
10
7.
On December 7, 1989, a Radwaste Plant Support Supervisor (RPSS)
and an Auxiliary Operator (AO) proceeded to the drum fill area
to resolve a drum indexing problem.
These individuals were
unaware until they reached the drum fill area that the high
radiation area boundary had been moved to the door of the drum
fill room.
The AO did not have a meter with him because his
turnover had indicated that the are~ was not posted as a high
radiation area.
The AO had checked the monitors in the Volume
Reduction System control room and noted no abnormal radiation
levels. *When the RPSS arrived at the drum fill room and saw the
unexpected boundary, the licensee determined that he disregarded
it for expedience of work and proceeded into the room to correct
the indexing problem.
The AO, who did not have a radiation survey
meter, followed the RPSS across the high radiation area boundary~
The AO knew the requirements for having a radiation survey meter
and that he was* not qualified to provide radiological covera~e.
The AO did not stop the RPSS from entering the area.
The individuals
were found in the posted high radiation area by the Radiological
Services Manager.
Upon subsequent investigation by the licensee,
it was d~termined that the RPSS was not qualified to provide self
monitoring and would have required radiological coverage to be in
confcirmance with llcensee procedures.
The licensee convened a management review board on the afternoon
- of December 7; 1989 to gather facts and to determine corrective
actions.
Two separate interviews were held; one with the AO and
one with the RPSS.
The licensee determined that the following
corrective actions should be taken:
(1)
Disciplinary action for the individuals involved would be
administered.
(2)
Evaluate the methods of posting and control for radioactive
waste volume reduction activities.
The inspectors reviewed the corrective actions taken by the
licensee.
Implementation of corrective actions appears to be
acceptable.
This is an apparent violation of Technical Specification 6.12.1
which requires that individuals permitted to enter a high radiation
area must be accompanied by a radiation monitoring device which
continuously indicates the radiation dose rate in the area or
be accompanied by an individual qualified in radiation protection
procedures who is equipped with a radiation dose rate monitoring
device.
(No. 255/90019-05)
One apparent violation and one violation was identified.
Planning and Preparation (IP 83750)
The inspector reviewed the outag~ planning and preparation performed
by the licensee, including: additional staffing, special training,
increased eq~ipment supplies and job related health physi~s
considerations.
11*
8.
The ihspector~ reviewed the status 6f the radiation protection and
radioactive material control readiness for the SGRP.
Some aspects of
the planning and preparation for this project have been discussed in
Sections 4 and 5 of this report.
Significant issues that have been
reso)ved by the licensee for this project include the following:
- use of temporary shielding, temporary ventilation, containments and
communications and video equipment to support radiological coverage.
An additional counting room has been setup to facilitate the timely
determination of air sample results. Respirator accountability and
control will be tracked by computer.
The effectiveness of the
respiratory protection program will be monitored by a sampling of
respirator users for whole body counts on a shiftly basis.
The licensee ~onducted a review of previous SGRP lessons learned.
These items were assign~d to responsible organizations and individuals.
Specific responses, positions and reasons for impact or non-impact were
elicited.
For those ~terns that could impact th~ success of the SGRP,
actions:were identified to address the concern.
In addition, the licensee
evaluated the critique items from the 1988 Refueling Outage.
These items
were also assigned to responsible individuals to address those concerns
that could impact the progress of the SGRP.
The majority of the items
that would present a immediate or short term concern have been addressed
by the licensee. The remaining items are cif a long term programmatic
improvement nature and are being tracked by the licensee for future
implementation.
Remaining issues that could affect the readiness for the. SGRP are as
follows.
First, the containment access facility was lagging behind
schedule and would not be ready by the staff of the outage .. Concerns
were expressed to the licensee that, given the increase in the number
of workers scheduled for the SGRP and limitations of the normal access
control point, there was -a significant potential for loss of control
by radiation protection personnel.
During the inspection, the licensee
and its contr~ctors initiated an additional shift of workers involved
in the construct'ion of this facility. The licensee reported to the
inspector*on September 19, 1990 that the containment access facility
was placed in service as of this date.
Additional concerns were
expressed regarding the containment of contamination in the containment
access facility structures and control of radioactive materials given
- the logistics and restricted space available at the plant.
The inspector
indicated to the licensee that these issues would be followed up during
a future inspection ..
No violations or deviations were.identified.
The inspector reviewed the licensee's program for maintaining
occupational exposures ALARA, including:
ALARA group staffing and
qualification; changes in ALARA policy and procedures, ahd their
implementation;ALARA considerations for planned, maintenance and
refueling outages; worker awareness and involvement in the ALARA
program; establishment of goals and objectives, and effectiveness
in meeting them.
Also reviewed management techniques, program
experience and correction of self identified program weaknesses.
12
.
The. inspector reviewed selected records and ALARA planning documents
and newly revised procedures for the plant and SGRP ALARA planning
efforts. It appears that most of the SGRP work packages have had
their initial ALARA reviews and evaluations.
No problems were noted.
Total exposure for plant activities to date was 137.8 person-rem.
Total contamination events for plant activiti~s to date ~as 101.
Total exposure for SGRP activities to date 25.8 person-rem.
Total
contamination events for SGRP activities to date was 18.
No violations or deviations were identified.
9.
Gaseous Radioactive Wastes (IP 84750)
The inspectors reviewed the licensee's gaseous radwaste management
program, including: changes in equipment and procedures, gaseous
radioactive waste effluents for compliance with regulatory requirements,
adequacy of required records, reports, and notifications, process and
effluent monitors for compliance with operational requirements and
experience concerning identification of programmatic weaknesses.
Sampling and release methods,. procedures, records and reports appear
adequate with some exceptio~s which iri discussed in Section 13.
The
inspectors reviewed the Semiannual Radioactive Effluent Release Reports *
for the last half of 1989 and for the first half of 1990.
Noble gas
effluent totals for th~ last half of 1989 were approximately 110 curies.
Noble gas effluent totals for the first half of 1990 were approximately
40 curies.
A comparison .with 1987-1988 gaseous radioactive effluent
release data indicates that the amount of noble gas released
significantly decreased in 1989 and 1990 to date (compared to 1746
curies and 2428 curies for 1987 and 1988 respectively) .. This reduction
is attributed to a much lower number of fuel failures and an effective
licensee valve improvement program.
Both programs appear to have been
effective in reducing gaseous effluent releases.
No problems were noted:
The inspectors reviewed the licensee's release permit program for
gaseous bat.ch releases and a selective number of gaseous release permits
is~ued in 1990.
No problems were ~oted.
No viol~tions or deviations were identified.
10.
Liquid_ Radioactive .Was.te (IP 84750)
The inspectors reviewed the licensee's liquid radioactive waste
management program, including: liquid radioactive waste effluents for
compliance with regulatory requirements, adequacy of required records,
reports, and notifications, process and effluent monitors for compliance
with operational requirements and experience concerning identification
and correction of programmatic we~knesses.
Sampling and release methods, procedures, records, and reports appear
adequate.
The inspectors selectively reviewed liquid batch release
permit records for 1989 and 1990; no significant problems were noted .
There were 14 and 4 liquid radioactive effluent batch releases for
1989 and the first half of 1990, respectively .
.i 3
The inspectors reviewed records of liquid radioactive effluent releases
for 1989 and the first half of 1990.
The total fission and activation
product releases for 1989 were 3.75 E-3 curies and the corresponding
totals for the first half of 1990 were 1.5 E-3 curies.
No violations or deviations were identified.
11.
Solid Radioactive Waste and Transportation (IP 83750, 84750)
The inspectors reviewed the licensee's solid radioactive waste
management program, including:
changes to ~q~ipment and procedures,
processing and control of solid wastes, adequacy of required records,
reports and notifications, performance of process control and quality
assurance programs and experi~nce in identificatipn and correction of
programmatic weaknesses.
The inspectors reviewed selected portions of the licensee's .solid
radwaste processing, storage and shipping records for 1989 and 1990
to date; no problems were noted.
The licensee's records indicate
that approximately 4500 and 2280 cubic feet of solid radwaste was
shipped in 1989 and the first half of 1990, respectively.
As of
September 12, 1990, the licensee had a ~otal of approximately 2300
- cubic feet of solid radwaste temporarily stored on site, awaiting
shipment to burial sites. The inspector toured the solid radwaste
processing, storage and shipment staging area; no problems were
noted.
No violations or deviations were identified.
12. * Transportation of Radioactive Materials and Radwaste (IP 83750, 84750)
The inspectors reviewed the licensee's transportation of radioactive
materials program, including: adequacy and implementation of written
procedures, radioactive materials and radwaste shipments for
compliance with NRC and DOT regulations and the licensee's quality
assurance program, review of transportation incidents involving
licensee shipments (if any), adequacy of required record~, reports,
shipment documents and notifications and experience concerning
identification and correction of programmatic weaknesses ..
The inspectors selectively reviewed portions of the radwaste shipment
records for 1989 and to date in 1990.
The information on the shipping
papers appears to satisfy NRC, DOT, and.burial site requirements.
No violations or deviations were identified.
13.
Effluent Reports
The inspector selectively reviewed radiological effluent analysis
results to determine the accuracy of data reported in the Semiannual
Radioactive Effluent Release Reports.
14
A licensee review of the July-December 1989 Semiannual Report revealed
that the Meteorological data used in the preparation of the report
(GASPAR code) did not match the Meteorological data contained in
Palisades Offsite Dose Calculation Manual (ODCM) and was slightly* less
conservative.
This resulted in a nonconservative error of about 2% in
the integrated total body doses to the general population and the
average doses to individuals (adults) within the general population
from gaseous effluents releases within a distance of 50 miles from the
site boundary.
Further licensee investigation revealed that this same
meteorological data was used in the preparation of the 1985 through *
1989 Semiannual reports.
The GASPAR meteorological input files were
corrected prior to the preparation of the 1990 January-June Semiannual
Report.
The fa,ilure to provide accurate information to the Commission by the
licensee is contrary to 10 CFR 50.9.(a) Completeness and Accuracy of
Information, which requires, in part, that information provided to
the Commission andrequired by the Commissions regulations shall be
complete and accurate in all material aspects.
The inaccuracy
remained undetected for five years because of the lack of procedural
guidance requirin~ checking all Semiannual Report inputs prior to
issuance.
On September 19, 1990, the licensee initiated the*
following -corrective actions before the inspecfion ended: -
a.
Procedure HP 10.5, Palisades Semiannual Radioactive Effluent
Release Report Procedure, was revised to include a requirement
to ensure all data is complete and accurate.
b.
Computer codes were reviewed for s6ftware*quality assurance
app 1 i cabil i ty.
c.
Doses to the integrated whole body and the average doses to
individuals within the general population from gaseous releases
within a distance of 50 miles from the sit_e boundary for the time*
period affected by this error were recalculated.
The results
would be submitted in an addendum to the next Semiannual
Radioactive Effluent Release Report.
Since this event was identified by the licensee, response was timely,
corrective actions appear to be adequate and the event does not
appear to be recurrent, pursuant to Section V.G.1. of Appendix C to
10 CFR Part 2, a Notice of Violation will not be issued for this
Severity Level IV violation.
This matter is closed. (NCV No.
255/90019-06)
The inspect"ors selectively reviewed Semiannual Radioactive Effluent
Rele~se Reports for the last half of 1989 and the first half of 1990
which are required by Technical Specification 6.9.3.1.A.
No
additional problems were noted.
One non-cited violat~on was identified .
15
'-----'
14.
Effluent Instrumentation
15.
17.
The inspector reviewed the records for effluent control instrumentation
surveillance/operability, including reports to the*NRC required by
Techoical Specifications.
The inspectors selectively reviewed calibration, channel function,
and alarm set point procedures and results for effluent control
instrumentation on the gaseous and liquid systems (Hi Range Noble Gas
Monitor and Radwaste Discharge Monitor).
Calibration methods appear *
appropriate and meet Technical Specification requirements.
No
problems were noted.
No violations or deviations were identified.
Primary Coolant Radiochemistry (IP -84750)
Technical Specification 3.1.4 requires that the specific activity of
the primary coolant not exceed one microcurie of 1-131 dose equivalent
per gram except under certain limiting .conditions of operation. The
inspector selectively reviewed the licensee's primary_coolant radio-
chemistry results for 1988, 1989 and l990 to date, to .. determine
compliance with the Technital ~pecification requirements for the
1-131 dose equivalent (DEI-131) concentration. The selective review
and discussion with licensee personnel indicated that the DEI-131
concentration for the primary system remained less than the applicable
Technical Specification limit throughout the review period.
No violations or deviations were identified.
Air Cleaning Systems (IP 84750)
Technical Specifications (T/S) require filter testing of the Control
Room Ventilation and Isolation System (CRVIS, VF-26) and the Fuel
Storage Area HEPA/Charcoal Exhaust System (FSAES, VF-66) as specified
by Surveillance Requirement Table 4.2.3, HEPA Filter and Charcoal
Adsorber Systems.
The in-place leakage test criterion specified for
both the DOP testing of HEPA filters and freon testing of charcoal
adsorbers is equal to or less than one percent penetration.
The laboratory test criterion for carbon sample removal efficiency
for methyl iodide is equal to or greater than 94 percent.
Procedure
No. RT-85C,D and Technical Specifications Surveillance Procedure
Basis Document for In Place HEPA and Charcoal Filter Testing,
Revision 1, August 7; 1989, establish more stringent filter testing
requirements for VF-26 in that the CRVIS in-place leakage test
criterion specified for both the DOP testing of HEPA filters and
freon testing of charcoal adsorbers is equal to or less than 0.05
percent penetration. The laboratory test criterion for carbon sample
removal efficiency for methyl iodide is equal to or greater than 95
percent; the test criteria for the FSAES (VF-66) are the same as the
T/S Surveillance Requirements. A selective review of surveillance
tests data for 1989-1990 showed that the survei 11 ances for the above
ventilation systems had met test acceptance criteria.
16
In response to an inspector concern regarding methyl iodide testing of
charcoal adsorbers, the licensee has:
a.
Implemented testing methodology specified by NRC for laboratory
tests of methyl iodide removal efficiency.
(ASTM 03803-89)
b.
Revised Purchase Order No. CP 14-139-Q to their vendor, Nuclear
Consulting Services, Inc, to require testing to ASTM 03803-89
for charcoal samples and for refilled trays of charcoal prior to*
being shipped to the licensee.
c.
Evaluated the adequacy of the testing equipment and methodology.
d.
Revised appropriate system operating procedures and operating
department checklists to assure to the extent possible, that
adsorber contaminating fumes are not drawn into the air cleaning
systems during operations. This matter is considered resolved.
No violations or deviations were identified.
18.
Plant Tours (IP 83750, 84750)
The inspectors performed several tours of radiologically controlled
areas.
These included walkdowns of fuel, auxiliary, turbine and
radwaste buildings.
The inspectors observed the following:
Radiation workers access and egress from the RCA; personnel
use of frisking stati~ns, portal monitors and electronic
dosimetry were acceptable.
contamination monitoring, portabl.e survey, area radiation
monitoring instrumentation in use throughout the plant;
instrumentation observed had been recently source checked
and had current calibrations, as appropriate.
The setup for a radwaste shipment, surveys, placarding of the
transport vehicle and shipping documentation;
radiological
controls and waste transfer were in accordance with regulatory
requirements and approved station procedures.
Posting and labeling for radiation, high radiation, contaminated
and radioactive material storage areas; with the exception noted
in Section 6 of this report, posting and labeling were in accordance
with regulatory requirements and approved station procedures*.
Housekeeping and material condition; with the exception noted
below, housekeeping and material conditions were very good.
Housekeeping and material conditions in the spent fuel pool heat
exchanger room and particularly in the boric acid pump/storage tank
room were poor. * In the boric acid pump/storage tank room, there appears
to be some evidence of chemical attack on some structural supports and
components.
During the inspection, the licensee commen~ed a cleanup
17
.
'"
of the boric acid pump/storage tank room and-scheduled repairs to th~
leaking boric atid pump for the refueling/SGRP outage.
Initial
evaluations by the licensee indicated that the pump leakage was due
to .a loose seal retainer. This was caused by high vibration due to
a pump misalignment.
The licensee indicated that an evaluation of the
integrity of components, fasteners and supports in this room would be
performed.
This matter will be reviewed during a future inspection by
the resident inspectors. (Open Item 255/90019-07(DRP))
No violations or deviations were identified.
One open item was
identified.
19.
Fire in B Radwaste Evaporator Room
On August 13, 1990, a fire started in the B radwaste evaporator room.
The fire was located in new heat tracing that was installed under new
insulation on the lines from the evaporator.
The cause of the fire
reportedly was a short in the heat trace line.
At the onset of the
fire, workers were in the room installing new insulation on the
evaporator lines.
An RP technician was also in the room providing
radiological coverage for the ongoing work.
The fire was reported,
an alarm was sounded and an announcement was made over the public
address system.
-
-
A fire extinguisher was given to the RP technician by a support worker
from outside the evaporator room.
The RP technician had extinguished
the fire by the time the ffre response team arrived.
This team arrived
within minutes of the announcement; fully equipped for a fire in a
contaminated area.
The inspector reviewed the area of
actions of the personnel involved.
thinking of personnel involved are
performance.
the fire, damage incurred, and the
The timely yesponse and quick
representative of excellent
No violations or deviations were identified.
20.
Exit Interview (IP 30703)
The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of .the onsite inspection on September 14, 1990 and by
telephone through September 19, 1990.
The inspectors summarized the
scope and findings of the inspection. The inspectors discussed the
likely informational content of the inspection report with regard to
documents or processes reviewed by the inspectors during the inspection.
Licensee representatives did not identify any such documents or processes
as proprietary.
The fo 1lowi ng matters were discussed specifically by the
inspectors:
a.
The apparent violations.
(Sections 4.c and d, 6.b and 13)
b.
Inspector concerns regarding the scope of the Quality Assurance
Surveillance Program.
(Section 5, Open Item No. 255/90019-03)
18
c.
Inspector concerns for the material condition in the spent fuel pool
heat exchanger and the boric acid pump/storage tank room (Section
18, Open Item No. 255/90019-07(DRP))
19
I
.