ML18057B185
| ML18057B185 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/19/1991 |
| From: | Caniano R, Markley A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B183 | List: |
| References | |
| 50-255-91-11, NUDOCS 9108010170 | |
| Download: ML18057B185 (6) | |
See also: IR 05000255/1991011
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/91011(DRSS)
Docket No. 50-255
Licensee: Consumers Power Company
27780 Blue Star Memorial Highway
Covert, MI
49043
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted:
June 25-27, 1991
&P / c~~~- --1~
~: Markley, Radfu'i~n Specia 1 ist
Inspector:
~~
Approved By:
- Caniano, Chief,
ological Controls and
mergency Preparedness Section
Inspection Summary
License No. DPR-20
/-117-7'/
Date
7--/f'-V
Date
Ins ection on June 25-27, 1991 (Re ort No. 50-255/91011(DRSS))
Areas Inspecte : Specia , unannounce
rnspect1on to review a legations
concerning inadequate implementation of the radiation protection and training
programs.
The allegations related to the utilization of unqualified contract
radiation protection technicians, failure to perform surveys during the
reactor head set evolution, and a deliberate hot particle exposure.
Results:
One violation was identified pertaining to a contract health physics
technician performing duties prior to completing qualification requirements.
The concern regarding the deliberate hot particle exposure with no
documentation and a lack of management response was partially substantiated
in that a deliberate hot particle exposure did occur and the event was not
doc-umen-ted. =The con-cern regarding th=e =fa=; lure to perform -and~ Clocument surveys
to identify an 8 R/hour hot spot during the reactor head set evolution was not
substantiated. However, a concern was identified regarding the timeliness of
review and dissemination of radiological information associated with the
reactor head set evolution (Section 2) *
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DETAILS
1.
Persons Contacted
- A. Clark, General Health Physicist
- P. Donnelly, Director, Plant Safety and Licensing
J. Fontaine, Senior Health Physicist
- K. Haas, Radiological Services Manager
- R. Henry, Radiation Protection Supervisor
R. Hill, Radiological Services Technician
- L. Kenaga, Health Physics Superintendent
G. List, Refueling Engineering Supervisor
- D. Malone, ALARA Supervisor
- M. Mennucci, Senior Health Physicist
- T. Neal, Radioactive Materials Administrator
- T. Palmisano, Administrative and Planning Manager
- J. Petro, Quality Assurance
- P. Rigozzi, Training Supervisor
- D. Rogers, Training Administrator
- G. Slade, Plant General Manager
- R. Roton, Resident Inspector
- E. Schweibinz, Senior Project Engineer
The inspectors also interviewed other licensee and contractor personnel
during the course of the inspection.
- Denotes those present at the exit meeting on June 27, 1991.
- Contacted by telephone on July 2, 1991.
2.
Allegation Follow-up (IP 99024)
Discussed below are several specific allegations relating to the inadequate
implementation of the radiation protection and training programs which
were evaluated during this inspection. The evaluation consisted of record
and procedure reviews and interviews with licensee personnel.
(Closed) Allegation (AMS No. RIII-91-A-0036)
Concern:
Contracted health physics technicians performed duties and
functions prior to having completed their qualification requirements.
Discussion:
The inspectors reviewed the Palisades Steam Generator
Replacement Project Radiological Plan and licensee procedures to
determine the nature of the contract health physics technician (HPT)
training and qualification requirements. The entrance examination was
determined to be administrative in nature and was used for initial
screening and knowledge level evaluation. The Palisades Steam Generator
Replacement Project (SGRP) Radiological Plan Section III.D.2 states that
Qualification training will consist of three phases:
Formal classroom
procedure training, on-the-job training (OJT) and informal continuing
training throughout the project.Section III.D.2.a. requires that
2
senior HPTs must pass the procedure qualification exam with a score of
at least 80 percent and junior HPTs must score at least 70 percent.
Section III.D.2.a also allows waivers for the procedure exam to be
granted for contract HPTs who have been incumbent within the last twelve
months.
Waived technicians must receive training on procedure changes
which may have occurred during the past twelve months and may impact
radiation protection (RP) functions.
Procedure HP 1.1, Sections 3.6
and 4.2, and Attachment 14, Item F require that radiation safety
technicians shall successfully complete required classroom training
prior to performing On-the-Job tasks and complete procedure training
before being permitted to work independently.
The inspectors reviewed the training records and examinations to
identify contract radiation protection (RP) personnel who had failed
entrance and procedure qualification exams.
As a result of problems
associated with examination grading and discussed in Inspection Report
50-255/90028(DRSS) and Enforcement Conference Report 50-255/90035(DRSS),
a new answer key was developed and the procedure qualification
examinations were regraded. This resulted in thirteen procedure
qualification examination failures. These individuals had initially
passed the procedure qualification exam that was given during the
normal training sequence.
Each individual had passed the on-the-job
training portion of their qualification. However, the passing of the
procedure qualification examination was a prerequisite to independent
performance of duties and functions.
The licensee identified all
thirteen individuals as being restricted from performance of duties
and functions until the procedure qualification examination could be
passed.
The two individuals who were named in the allegation had been
incumbent as HPTs within the last twelve months and were waived from
retaking the procedure examination.
The waiving of the two individuals
appears to have been performed in accordance with the licensee's
procedures.
The inspectors evaluated the number of times each individual was given
the opportunity to take entrance and procedural qualification exams.
With respect to the procedure qualification exam, the inspectors found
no evidence to indicate that any individual had taken this exam more
than two times.
In all cases evaluated, each individual passed the
second procedure qualification exam.
One individual was identified as
unable to pass the entrance exam.
This individual had been incumbent
as an HPT within the last twelve months. This individual's performance
was evaluated by licensee management, determined to be acceptable and
was waived-from the entrance examination. The performance nf all
individuals who had failed either the entrance or procedure qualification
examinations was evaluated by licensee management.
These reviews were
completed on November 5, 1990 with no problems noted.
The inspectors reviewed radiation and contamination surveys, radiation
occurrence reports, and radiation work permits for indications of
independent performance of duties and functions. These records were
compared to the list of individuals whose duties were restricted until
the procedure qualification examination was passed.
The inspectors
identified three sets of radiological surveys, air sampling and
3
'*
evaluations that were performed by an individual who was on the restricted
duty list. This individual had not been previously identified in the
allegation. The restricted time frame for this individual was from
October 11-18, 1990.
The surveys were performed on October 11, 1990 for
the removal of the end bells of the spent fuel heat exchanger (Radiation
Work Permit (RWP) No. 90-1039), October 13, 1990 for cleaning and
rebuilding of the control rod drive mechanisms (RWP No. 90-1020), and
October 16, 1990 for overhaul and decontamination of the control rod
drive mechanisms (RWP No. 90-1020).
No evidence was found or identified
by the licensee that indicated that this individual had received direct
supervision in the performance of the aforementioned tasks.
Finding: This allegation was partially substantiated.
No evidence was
found to indicate that individuals were given multiple opportunities to
pass the procedure qualification examination.
Each technician who was
identified as having failed the procedure qualification exam either
passed the exam on their second attempt or were waived in accordance
with the licensee's procedures.
One individual was identified as
unable to pass the entrance examination.
However, since this examination
was administrative in nature and was not a part of the qualification
program, there is no regulatory basis or requirement for utilizing or
passing this exam.
One individual was identified who performed duties and functions as an
HPT during the period in which his qualification had been suspended
because of procedure qualification exam failure. The performance of
duties and functions by contract HPTs prior to completion of qualifi-
cation requirements is a violation {Violation No. 255/91011-01).
The
corrective actions that were specified in Enforcement Conference Report
50-255/90035(DRSS) appear adequate to prevent recurrence of this type
of event.
{Open) Allegation (AMS No. RIII-91-A-0041, Item 1)
Concern:
Deliberate hot particle exposure occurred with no
documentation and a lack of management response.
Discussion:
The planned scope of this inspection involving this concern
was limited to determining whether the licensee's corrective action
program required identification, determination of root cause and
implementation of corrective actions to preclude recurrence of a
potential license violation. Administrative Procedure 3.03, Corrective
Action, Section 5.1 and 5.1.b require-that an £vent Report shall be
issued for conditions that may be reportable to the NRC or other
regulatory agencies, including potential violations of license
requirements.
The procedural requirements were then cross checked
with radiation incident reports, radiological deficiency reports,
deviation reports and event reports from September 1990 to date to
determine whether the licensee had documented the deliberate hot
particle exposure.
As of the end of the inspection, the licensee had
not documented this incident in a corrective action document.
4
During the course of this inspection, the licensee provided an
unrequested written summary regarding the alleged deliberate hot
particle exposure. This information acknowledged that on
November 15, 1990, a contract senior HPT had deliberately taped a hot
particle (180,000 dpm) that was contained within a plastic planchet
which was within a plastic bag onto the back of a contract health
physics operations supervisor.
The licensee indicated that dose
assessments were performed.
The licensee's assessment determined
since the particle was low in activity, was sealed in a planchet and
plastic bag and was on the outside of the individuals.'s clothing their
was no radiological consequences surrounding the event and exposure to
the individual was below any regulatory limit.
The licensee's summary
also indicated that the licensee had desired to terminate the contract
senior HPT's employment for poor performance.
However, the individual
was officially released from employment to reduce staff.
Finding: This concern was partially substantiated in that a deliberate
placement of radioactive material on the back of an individual occurred.
It does not appear, however, that this event resulted in an exposure to
the individual in excess of any regulatory limit. Since the placement
of the hot particle on a person is not an authorized licensed activity,
it appears that the licensee was under an obligation to document this
incident in a corrective action document yet failed to do so. Additional
inspection efforts will be forthcoming to further review this issu~ and
also to review the adequacy of management's response to the event. This
allegation therefore will remain open (AMS No. RIII-91-A-0041)
(Closed) Allegation (AMS No. RIII-91-A-0041, Item 2)
Concern:
Failure to perform and document surveys to identify an 8
R/hour hot spot in the reactor flange area during the reactor head
set evolution in January 1991.
Discussion: The inspectors reviewed radiological surveys associated
with the reactor head set, cavity decontamination and cavity seal
removal evolutions.
In addition, radiation protection logs were
reviewed and interviews were conducted with licensee personnel involved
with these activities. Copies of surveys were obtained from the Document
Control Facility. The licensee provided the following chronology of
events. At 10:30 AM on January 30, 1991, the reactor head was set on
the flange and the guide pins were removed.
At 11:00 AM on January 30,
1991, a cavity after-head-placement/pre-decon survey was documented that
identified 8 R/hr and 1 R/hr hot spots in the flange/seal area of the
reactor cavity. General equipment movement and placement of the upper
guide structure lift rig to the southeast corner of the cavity occurred
during the time period from 11:00 AM until after midnight on January 31,
1991.
Cavity decontamination commenced until a cavity post decon survey
was documented at 7:00 AM on January 31, 1991. This survey did not
identify any unusually high dose rates or contamination levels.
The
8 R/hr hot spot appears to have been removed during the reactor cavity
decontamination efforts .
5
A radiation work permit (RWP) No. 91-1327 was written to perform reactor
cavity seal removal at 11:00 AM on January 31, 1991.
RWP No. 91-1327
reflected the radiological conditions that existed prior to cavity
decontamination.
Further reviews of this RWP indicated that it was
revised in the field to reflect post decontamination radiological
conditions prior to job performance.
The inspectors also reviewed
personnel dosimetry results, both whole body and extremity, associated
with these activities.
No unusually high exposures were identified.
Finding: This concern was not substantiated. The 8 R/hr hot spot
appears to have been removed during the reactor cavity decontamination.
Documented surveys identify both the finding and elimination of the
8 R/hr hot spot as well as a 1 R/hr hot spot.
However, improvements
may be warranted in the timeliness of review and dissemination of
radiological information.
Four hours had elapsed between the post
decontamination survey and the generation of an RWP that required
this updated information to specify radiological safety requirements.
This delay would cause more concern had the radiological conditions
deteriorated rather than improved.
During the course of the inspection
the licensee indicated that this matter will be reviewed to determine
what appropriate actions may be necessary to improve on the timeliness
of reviewing and disseminating radiological information.
(Open Item
No. 255/91011-02)
One violation and two open items were identified.
3.
. Exit Interview (IP 83750)
The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on June 27, 1991, to discuss the
scope and findings of the inspection.
During the exit interview, 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 following items were specifically discussed with the
licensee.
a.
The need for additional inspection and review of the deliberate hot
particle exposure event by NRC.
b.
The apparent violation associated with a contract HPT performing
duties prior to completing qualification requirements.
c.
Inspector concerns regarding the timeliness of review and
dissemination of radiological survey information.
6