ML18057B404
| ML18057B404 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/29/1991 |
| From: | Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B402 | List: |
| References | |
| 50-255-91-22, NUDOCS 9112110082 | |
| Download: ML18057B404 (13) | |
See also: IR 05000255/1991022
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/91022(DRSS)
Docket No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
Palisades Nuclear Generating Plant
27780 Blue Star Memorial Highway
Covert, MI
49043
Facility Name:
Palisades Nuclear Gen~rating Plant
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted:
October 30 through November 6, 1991
C., "1. )J;ll JD~
. A. w. Markley r
I
Inspector:
11/z 9/q1
c.~~)~
Date
Approved By:
William Snell, Chief
Radiological Controls and
Emergency Preparedness Section *
Inspection Summary
Inspection on October 30 through November 6, 1991 (Report No.
50-255/9l022(DRSS))
Areas Inspected:
Routine unannounced inspection of the radioactive waste
management, effluent monitoring ahd transportation programs, including:
organization, management controls and training, gaseous radwaste, liquid
radwaste, solid waste and transpGrtation, effluent reports, effluent control
instrumentation, primary coolant ichemistry and air cleaning systems (IP
84750, 86750).
Reviewed open items from past identified concerns (IP 83750,
84750, 86750).
Results:
One violation was identified that involved the performance of an
inadequate 10 CFR 50.59 review of the reactivation of the south radwaste
building for radioactive waste storage and its associated Final Safety
Analysis Report changes (Section 7).
A non-cited violation was identified
for control of radioactive sources (Section 10).
One Unresolved Item
associated with the implementation of 10 CFR 50, Appendix A, Design Criteria
61, 63, and 64 for radioactive waste processing and storage facilities, and
associated with the construction of radioactive waste processing facilities
to a standard different than that identified in the Fina] Safety Analysis
Report was identified (Section 8).
One open item associated with the
licensee's implementation of the 10 CFR 20 definition of a restricted area
was identified (Section 10). *
9112110082 9111?9
ADOCK 05000255
Q
However, the organizational structure, management control5, staffing levels,
and upper management support for the radwaste/transportation program appeared
generally adequate.
Improved performance was noted in continued reductions in
gaseous effluents and in reduction of the generation of solid radioactive waste.
Liquid radioactive effluents remain less than one percent of the annual
Technical Specification li~its.
No problems were identified with th~ radwaste
shipping and transportation program .
2
l.
DETAILS
Persons Contacted
- D. Anderson, NPAD
- A. Clark, General Health Physicist
- P. Donnelly,_ Director, Plant Safety and Licensing
M. Grogan, Radwaste Coordinator
- K. Haas, Radiological Services Manager
R. Henry, Radiation Protection Supervisor
- L. Kenaga, Health Physics Superintendent
- J. Kuemin, Licensing Administrator
- D. Malone, ALARA Supervisor
- M. Mennucci, Senior Health Physicist
T. Neal, Radioactive Materials Admini.strator
- W. Roberts, Licensing Engineer
- G. Slade, Plant General Manager
- R. Vincent, Plant Safety Engineering
- J. Werner, NPAD
- J. Heller, Senior Resident Inspector
- R. Roton, Resident Inspector
The inspectors also interviewed other licensee personnel during the
course of the inspection.
- Denotes those present at the exit meeting on June 27, 1991.
2.
Genera 1
This inspection was conducted to review aspects of the licensee's
radw~ste management, radioactive ~aterial shipping, effluent monitoring
and transportation programs.
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, radwaste facilities, observations of licensee activities, revi~w
of representative records and discussions with licensee personnel.
3.
Licensee Action on Previous Inspection Findings (IP 92701)
(Closed) Open Item No. 255/89030-01:
Evaluate the adequacy of MPC-HR
estimation methodology.
The licensee has revised HP 8.2, Whole Body
Count Evaluation Procedure, to incorporate ICRP-30 methodology as
implemerited by NUREG/CR-4884 for those short lived isotopes for which
ICRP-10 methodology could result in a nonconservati~e dose assessment.
This item is closed.
(Closed) Open Item No. 255/90012-02:
Pumping of contaminated water from
the C-Bus cable pit to the turbine sump.
The licensee's investigation
concluded that the contamination of the water in this pit was ~he result
of past spills and the pulling of cables through this area.
The licensee
accounted for the activity released and established procedure and ~ork
permit controls to ensure that water was sampled and analyzed prior to
removal from this pit. This item is closed.
3
i-
{Closed) Open Item No. 255/91006-01:
Evaluate the methodology utilized
to assess skin dose due to hot particles.
The licensee has revised
-
procedure HP 2.42, Evaluation of Dose to the Skin Due to Personnel Skin
Contamination.
This revision will ensure th~t the gamma ~omponent of
dose to the skin is ev~luated for exposures greater than one microcurie
hour and that beta self absorption of the p~rticle is evaluated. This
item is c_losed.
(Closed) Violation No. 255/91006-02:
Failure to control, calibrate and
operationally check health physics portable instrumentation.
The.
licensee.has taken actions to address the causes of these events and to
improve personnel performance.* These actions include: *disposal of the
uncontrolled instrument, counseling of involved health physics personriel,
issuing a memo to all radiation protection personnel regarding adherence
to procedural requirements, and discussion of technician *performance
issues at a Radiation Safety Department meeting.
In addition, contract
radiation protection training was reviewed and this event was added to
the refueling outage critique list. This violation is closed.
4.
Organization, Management Controls and Training (IP 83750, 84750, 86750) *
The inspectors review~d the licensee's organization and ~anagement
controls for the radwast~ and 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.
5.
The licensee's radwaste organization is a part of the Radiation Safety
Department.
This group is headed by a Radioactive Materials
Administrator who supervises a radwaste supervisor/coordinator, a
decontamination services supervisor and a support staff. This
_
organization is responsible for:
solid radioactive waste processing,
packaging, and shipping; radiological decontamination efforts;
preparation and cbntrol of gaseous and liquid radi6active releases;
preparation of semiannual effluent release and environmental monitoring
reports; and hazardous material control program.
Since the generation of
solid radioactive waste has been significantly reduced; the radioactive
w~ste handler group has become a pa~t time work force.
This group has
been shifted to the decontamination staff.
The Operations Department
operates the Volume Reduction System.
The licensee brought a vendor onsite to train radwaste personnel,
technicians and supervisors, and the nuclear operations assessors in
Radwaste Packaging in September 1991.
The Radwaste Supervisor attended
an Advanced Radioactive Material Shipping course in August 1991.
No violations or deviations were identified.
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,
4
adequacy of required records, reports, and notifications, process and
effluent monitors for complia*nce with operational requirements and
experience concerning identification of programmatic weaknesses.
The inspector reviewed selected records of radioactive gaseous effluent
releases and semiannual effluent reports for 1990 and 1991 to date.
The gaseous pathways and the sampling and monitoring program remained
essentially as previously reported.
In 1990, the plant released
approximately 41.4, 3.07E-3, and 5.58 curies of noble gas, radioiodine,
and tritium, respectively.
The corresponding values for the first half*
of 1991 were 0.24, 4.69E-5 and 2.71 curies, respectively.
The number of
gaseous releases and curie content of the releases have declined markedly
since 1989. _This improvement appears to be indicative of improved fuel
performance and improved system integrity.
The following summarizes the
licensee's gaseous releases (amounts are in curies) since 1989,
inclusive.
1989
1990
1991
Quarter
Number
Activity
Number Activity
Number
Activity
First
18
30.9
10
9.6
9
1. 7
Second
11
13.2
9
33.3
5
1. 2
Third
5
86.8
10
2.3
Fourth
16
32.2
2
1.8 (SGRP)
Total
50
163. 1
31
47.0
14
2.9
The inspector reviewed the licensee's release permit program for gaseous
batch releases and a selected number of gaseous release permits_ issued in
1991.
No problems were noted.
No violations or deviations were identified.
6.
Liquid Radioactive Waste (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 weaknesses.
The inspector reviewed selected records of radioactive liquid effluents
released and semiannual effluent reports for 1990 and 1991 to date.
The
pathways sampled and analyses performed appeared to comply with technical
specification requirements.
The liquid effluent pathway and the sampling
and monitoring program remained essentially as previously reported.
In
1990, the plant total liquid effluent release consisted of approximately
7.75E-3 curies total activity (excluding tritium, alpha, and dissolved
.noble gases) and approximately 149 curies of tritium.
The corresponding
values for the first half of 1991 were approximately 9.7E-3 and 21.9. *
curies, respectively.
Liquid _releases remained less than one percent of
the annual technical specification limit.
The inspector also selectively
reviewed the liquid batch release permit program and associated
documentation for past releases; no problems were noted.
5,
- *
No violations or deviations were identified.
7.
Solid Radioactive Waste and Transportation (IP 86750)
The inspectors reviewed the licensee's solid radioactive waste management
program, including: changes to equipment and procedures, processing and
control of solid wastes, adequacy of required records, reports and
notifications, performance of process control and quality assurance
programs and experience in identification and correction of programmatic
weaknesses.
.
Since the State of Michigan had made little progress in siting a low
level radioactive waste site for the Midwest Compact, the three states
with existing low level waste sites banned all radioactive waste
shipments from the State of Michigan as of November 10, 1990.
The State
of Michigan has subseque~tly been expelled from the Midwest Compact.
As
of this date, radioactive waste generators within the State of Michigan
continue to store radioactive waste onsite.
With respect to Palisades,
the licensee has utilized approximately 50 percent of its medium to high
level waste storage capacity and approximately 65-70 perc~nt of its low
level radioactive waste storage capacity.
The licensee has submitted plans to the NRC to use the South Radwaste
Building for additional storage capacity.
The reactivation of the South
Radwaste Building would be done under a 10 CFR 50.59 evaluation (safety
evaluation) as a change in facility use.
The inspector reviewed the
safety evaluation associated with the reactivation of this facility for
radioactive waste storage and the associated Final Safety Analysis Report
(FSAR) changes.
While the safety evaluation, dated March 12, 1991,
addressed a number of technical issues and administrative concerns, it
failed to identify the projected contained source term, radioactive
material release pathways and dose impact to the public, evaluation of
the potential for radioactive material release during normal and abnormal
6perating conditions and accidents, and evaluation of the need for
filtration and radiation monitoring systems.
Failure to perform an
adequate safety evaluation is a violation of 10 CFR 50.59.
The licensee
acknowledged this violation at the exit meeting. (Violation 255/91022-01)
The licensee generates spent resin, evaporator bottoms, dry active waste
(DAW), activated components, and filter media, as solid radwaste.
Since
the ban on radioactive waste shipments in November 1990, the licensee has
had no waste shipments to dispos~l facilities.
Prior to the ban in 1990,
the licensee shipped 10,056.7 cubic feet of these wastes for burial.
These radioactive wastes consisted of approximately 361. 1 cubic feet of
filter media, 487 cubic feet of solidified evaporator bottoms, 693.2
cubic feet of dewatered resins, and 8,5]0.4 cubic feet of DAW.
Radioactive waste is currently stored onsite in the East Radwaste
Building (ERB).
The licensee performs supercompaction of DAW onsite in
the ERB as well as processing and packaging of noncompactable waste in
this facility.
The licensee uses a bitumin solidification process for
evaporator bottoms located in the auxiliary building .
One violation was identified.
6
8.
Radwaste Processing and Storage Facilities (IP 84750, 86750)
During tours and ~eviews of the planned utilization of radwaste
processing and storage facilities, the inspector expressed concern
regarding the implementation of design criteria for these facilities.
These concerns also appear to be applicable to radioactive material
storage facil.ities. The-original Final Safety Analysis Report (FSAR) and
the updated FSAR were reviewed to identify design criteria applicable to
the licensing of radioactive waste processing and storage facilities at
the Palisades Nuclear Generating Plant.
The licensee's updated FSAR, Chapter 5. 1, documents original and updated
design criteria from 10 CFR 50, Appendix A that are applicable to the
containment of radioactivity, the*monitoring of radioactivity and the
monitoring of radioactivity releases.
a.
Design Criterion 61 - Fuel Storage and Handling and Radioactivity
Control
FSAR Chapter 5.1.7.2 states that radioactive waste and other systems
which may contain radioactivity shall be designed to assure adequate
safety under normal and postulated accident conditions.
These
systems shall be designed with appropriate containment, confinement
and filtering systems.
The licensee's response to this criterion in the FSAR states that
radioactive waste and other systems which contain radioactivity
have been designed so that under normal and postulated accident
conditions, adequate safety is maintained.
The waste storage area
is shielded to permit operation within the limits of 10 CFR 20 and
is designed so that accidental releases of radioact~vity to the
environment are below 10 CFR 100 guideline values..
The licensee's East Radwaste Building (ERB) currently houses the
licensee's dry active waste (DAW) processing equipment.
This
consists of a super compactor, a sandblast areq and waste
segregation areas.
This facility contains both encapsulated.and
unencapsulated radioactive materials. This building also contains
medium to high level radioactive waste storage areas for dewatered
resins and spent filter media.
The ERB i? a large metal building
constructed over a concrete pad.
One half of this structure is
insulated and heated; the other half is not.
Although a thorough
walkdown of this facility was not performed, interviews with
licensee personnel indicated that this structure did not have any
installed containment, confinement or filtration systems.
The
filtration-systems that were utilized consisted of a ventilation
system intrinsic to the supercompactor and a portable HEPA system
attached to the sandblast area.
The South RadV1aste Building (SRB) had been previously decommissioned
due to floods from cooling tower overflows.
This flooding had
resulted in dispersal of radioactive materials into the surrounding
7
s6ils for which the NRC had granted a 10 CFR 20.302 approval for
disposal in situ earlier this year.
However, since the licensee has
been unable to ship radioa~tive waste to burial sites, the licensee
has determined that this facility will have to be reused as a
interi~ radioactive waste storage facility. - This is documented in
the licensee 1s letter to the NRC dated April 24, 1991 and FSAR
Chapter 11.4.2.2, Revision 12.
Interviews with licensee personnel
and information gathered from previous inspection reports indicated
that this facility had been utilized as a solid radioactive waste
processing and storage facility.
DAW was processed and packaged
for transportation by means of a shredder and a compactor.
This
facility also contains storage areas for medium to high level
radioactive wastes.
This building, like the ERB, is a metal
building constructed over a concrete pad.
Although a thorough
walkdown of this facility was not performed, interviews with
licensee personnel indicated that this structure did not have any
installed containment, confinement or filtration systems.
The licensee has a number of other buildings that are utilized as
radioactive materials storage facilities,
The construction of these
buildings consists of metal buildings constructed over concrete pads
or are metal shell pole barns.
Although thorough walkdowns of these
facilities were not performed, interviews with licensee personnel
indicated that these structures did not have any installed
containment, confinement or filtration systems.
The apparent failure to implement 10 CFR 50, Appendix A, Criterion
61 is an Unresolved Item pending additional information from the
licensee. (Unresolved Item 255/91022-02a)
b.
Design Criterion 63 - Monitoring Fuel and Waste Storage
FSAR Chapter 5.1.7.4 states that appropriate systems shall be
provided in radioactive waste systems and associated handling areas
to detect conditions that may result in excessive radiation levels
and to initiate appropriate safety actions.
The licensee 1s response to this criterion in the FSAR states, in
part, that the process monitoring system is designed to monitor,
indicate, record, and alarm so that actions either automatic or
manual can be taken to correct excessive radiation levels.
All
process systems which contribute to plant discharges are monitored
prior to entering the various discharge systems.
Area radiation
detectors are provided in the radwaste storage and handling areas to
monitor continuously and alarm radiation levels.
As discussed in the previous section, the ERB houses radioactive
waste processing, handling and storage functions.
The SRB formerly
housed radioactive waste processing, handling and storage functions.
The licensee currently plans to utilize the SRB as an interim
radioactive waste storage facility.
This is documented in the
licensee's letter to the NRC dated April 24, 1991 and FSAR Chapter
8
11.4.2.2, Revision 12.
Although thorough walkdowns of these
facilities were not performed, the inspector did not identify any
process or area radiation monitors utilized in either the ERB or
SRB.
Interviews with licensee personnel indicated that these
structures did not have any installed process or area radiation
monitors.-
The apparent failure to implement 10 CFR 50, Appendix A, Criterion
63 is an Unresolved Item pending additional information from the
licensee. (Unresolved Item 255/91022-02b)
c.
Design Criterion 64 - Monitoring Radioactivity Releases
FSAR Chapter 5. 1.7.5 states that means shall be provided for
monitoring effluent discharge paths for radioactivity that may be
released during normal operations, including anticipated. operational
occurrences and from postulated accidents.
The licensee's response to this criterion in the FSAR states that
the main paths of waste to the plant discharge points are
continuously monitored, the circijlating water discharge and the
plant ventilation stack. A comparison of the operational survey
and preoperational survey identifies whether any changes in local
environmental radiological activity are due to the operation of
the facility and to assure that effluent releases are as low as
reasonably achievable.
The results of the operational survey are
submitted to the NRC in accordance wit~ the Plant Technical
Specifications.
As discussed in the previous sections, the ERB houses radioactive
waste processing, handling and storage functions.
The SRB formerly
housed radioactive waste processing, handling and storage functions.
Although thorough walkdowns of these facilities were not performed,
interviews with licensee personnel indicated that these structures
did not have any installed monitors or other means to monitor releases
from these facilities.
The apparent failure to implement 10 CFR 50, Appendix A, Criterion
64 is an Unresolved Item pending additional information from the
licensee. (Unresolved Item 255/91022-02c)
d.
Design Class I Radioactive Waste Processing Facilities
FSAR Chapter 11.4, Solid Wast~ Management System, provides the
design basis and system description for the solid radioactive waste
systems at the Palisades Nuclear Generating Plant.
FSAR Chapter
11.4. 1, Design Basis, states that all permanent system processing
equipment is located in a CP Co (Consumers Power Company) Design
Class 1 building.
Onsite buildings, other than the auxiliary
building and service building addition used to temporarily store
packaged processed wastes and expended filter cartridge assemblies
9
undergoing decay before.packaging, are engineered structures
designed for storing radioactive wastes but are not seismically
qualified.
FSAR Chapter 11.4, Section 11.4.2.2 describes solid waste processing
methods.
This section also indicates that processing and storage
space is available in the east iadwaste building located outside the
Plant securjty fence which was built in 1980.
As discussed in the previous sections, the ERB houses radioactive
waste processing, handling and storage functions.
The SRB formerly
housed radioactive waste processing, handling and storage functions.
It appeared that these facilities were not constructed to Design
Class I criteria.
The ERB and the SRB are large metal buildings
constructed over a concrete pad.
The apparent failure to design and construct the ERB and SRB as
Design Class 1 facilities as described in the FSAR is an Unresolved
Item pending additional information from the licensee. (Unresolved
Item 255/91022-02d)
e.
Design Basis Reconstitution
The inspector evaluated licensee efforts in design basis
reconstitution regarding radioactive waste systems and structures
that house these systems.
Licensee personnel indicated that there
are no plans to perform design basis reconstitution efforts for
plant structures or radioactive waste systems.
f.
Licensee Response
The licensee began an investigation to identify documents and
records which could show that these concerns had been addressed.
This effort was somewhat hampered due to ava1lability of personnel;
however, gathering of this type of information could require
substantial research.
By the end of the inspection, the licensee
was unable to provide the necessary information to address these
concerns.
The licensee notified the inspector during the week
following the inspection that the licensee had suspended processing
of solid radioactive waste outside of the auxiliary building until
the design concerns were resolved.
One unresolved item was identified.
9.
Transportation of Radioactive Materials and Radwaste (IP 86750)
The inspector 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 records, reports, shipment documents and
lC
notifications and experience concerning identification and correction of
programmatic weaknesses.
The inspector selectively reviewed radwaste shipping records for 1990 and
radioactive material shipping records for 1990 and
19~1; no problems were
rioted.
The licensee has made numerous radioactive. material shipments to
its protective clothing laundry vendor, laboratories for sample analysis
and contaminated equipment to other licensees and vendors.
No
transportation incidents have occurred since the last inspection.
No violations or deviations were identified.
10.
Radioactive Material Control (IP 83750)
During a review of deviation reports, radiological incident and
deficiency reports, some problems with radioactive material control
were identified.
On July 19, 1991, the licensee discovered that the
radioactive source locker in the whole body count facility was left
unlocked.
This source locker contained two sources and one source was
found in the whole body counter.
One of these sources had decayed enough
to be considered as an exempt quantity.
While one of the two remaining
sources was an exempt quantity, the third source was a nonexempt
quantity.
The whole body count facility is located in the administrative
building which is located outside of the protected area.
While this area
is well within the the site boundary, it is accessible to the general
public and is considered an unrestricted area.
The licensee documented this event in both a radiological deficiency
report and a deviation report.
The licensee's investigation was thorough
and comprehensive.
Corrective actions included counseling of the
involved technician; sources were removed from the whole body count room
and placed in a safe in the protected area; a message was transmitted to
all radiation safety personnel expressing the expectation to control all
sources at all times; revise procedural controls to assure more positive
control of radioactive source~ and train personnel on procedural
revisions; and improve labeling of radioactive sources.
Some additional
performance problems in radioactive sriurce control were identified in
which appropriate corrective actions were implemented.
Failure to
control radioactive material in an unrestricted area is a violation of 10
CFR 20.207.
Since the criteria in Section V.G of the Enforcement Policy
were met, a Notice of Violation will not be issued for this Severity
Level IV violation. This matter is closed. (NCV 255/91022-03)
The inspector reviewed the licensee's program for control of radioactive
materials.
The licensee's definition of a restricted area as defined in
10 CFR 20 appears to be too all inclusive.
As defined in procedure HP
2.20, the restricted area at Palisades includes all the area within the
site *boundary.
This definition has implications regarding training
requirements as identified in 10 CFR 19. 12.
The licensee committed to
evaluate their definition of a restricted area.
This will be reviewed
in a future inspection. (Open Item 255/91022-04)
One non-cited violation and one open item were identified .
11
11.
Effluent Reports (IP 84750)
The i~spector selectively reviewed radiological effluent analysis result~
to determine the accuracy of data reported in the Semiannual Radioactive
Effluent Release Reports for 1990 and the first half of 1991.
The
licensee use the sum of ra-dioisotopes method for determining the total
effluents, both gaseous and liquid.
No inconsistencies or inaccuracies
were noted.
No violations or deviations were identified.
12.
Primary Coolant Radiochemistry (IP 84750)
Technical Specification 3.1.4 re~uires that the specific activity of
the primary coolant not exceed one microcurie of I-131 dose equivalent
(DEI-131) per gram except under certain limiting conditions of operation.
The inspector selectively reviewed the licensee's primary coolant
radiochemistry results for 1991 to date to determine compliance with the
Technical Specification requirements for the 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.
13.
Air Cleaning Systems
The inspector reviewed recent testing result records of air cleaning
system filters, including laboratory analyses for methyl iodide removal
efficiencies of charcoal adsorber samples, and in-place penetration
(bypass leakage) testing of HEPA and charcoal adsorber filters.
The
tests appeared to have been conducted in accordance with Technical
Specification requirements and yielded results which met acceptance
criteria for leakage and removil efficiencies.
The inspector also
verified that maintenance for specific deficient equipment conditions
had been performed.
No violations or deviations were identified.
14.
Plant Tours (IP 83750, 84750, 86750)
The inspector performed tours of several radiologically controlled areas
(RCAs), including the south radwaste building, the east radwaste building
and several radioactive material storage areas.
The inspector observed
the fo 11 ovli ng:
Radiation worker access and egress from the RCA;
personnel use of
frisking stations and portal monitors were acceptable.
Contamjnation monitoring and portable survey instrumentation
utilized throughout the plant had been recently source checked and
had recent calibrctions, as appropriate.
Posting and labeling for radiation, high radiation, contaminated
12
~---------------------
and radioactive material storage areas were in accordance with
regulatory requirements and approved station procedures.
Housekeeping and material conditions in the east radwaste building
were generally poor.* Reportedly, significant work activities had
occurred in this area prior to the inspection.
Some problems with
open storage containers, a few instances in which contaminated
materials extended beyond the contaminated area and loaded step off
pads were noted.
No violations or deviations were identified.
15.
Unresolved Items.
Unresolved Items are matters about which more*information is required
in order to ascertain whether they are acceptable items, items of
noncompliance, or deviations.
The specific Unresolved Items are
identified in Section 8 of this report.
16.
Exit Interview (IP 30703)
The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on November 6, 1991 to discuss the
£cope 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
propriet~ry. The following items were specifically discussed at the exit
meeting.
a.
The apparent violations (Sections 7 and 10).
b.
- Inspector concerns regarding the implementation of design criteria
in radioactive waste processing and storage and radioactive material
storage facilities (Section 8).
The inspector discussed the
probability that information regarding these items would be
requested by the NRC. ;
c.
Inspector concerns regarding the licensee's definition of the
restricted area versus the definition in 10 CFR 20 (Section 10)
13