ML18057A879

Responds to NRC 910329 Ltr Re Violations Noted in Insp Rept 50-255/91-06.Corrective Actions:Ludlum 177 Count Rate Meter Removed from I&C Lab & Disposed of & Radiological Deficiency Rept Initiated

ML18057A879
Person / Time
Site:	Palisades
Issue date:	04/29/1991
From:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9105080006
Download: ML18057A879 (3)

See also: IR 05000255/1991006

Text

l'OWERINli

MICHlliAN§S

l'ROliRESS

Palisades

Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 29, 1991 Nuclear Regulatory

Commission

Document Control Desk* Washington, DC. 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT -RESPONSE TO INSPECTION

REPORT 91006; NOTICE OF VIOLATION

GB Slade * General Manager Nuclear Regulatory

Commission (NRC) Inspection

Report 91006, dated March 29, 1991, documented

the results of a routine safety inspection

and reported the issuance of two violations

for: (1) the use of uncontrolled

health physics portable laboratory

measuring

and test equipment

in the plant and (2) the use of uncontrolled

vendor manuals in the plant. The following

is Consumers

Power Company's

response to these violations.

Violation

50-255/91006-02

Technical

Specification

6.11 requires that procedures

for personnel

radiation

protection

shall be approved, maintained

and adhered to for all operations

involving

radiation

exposure.

• Administrative

Procedure

7.01, "Health Physics Portable Instrumentation

Program", requires that all health physics instrumentation

shall be calibrated, have operational

checks performed

once per day, shall be serialized

and shall have calibration

stickers placed upon them. -Contrary to the above, on March 7, 1991, a Ludlum Model 177 (count rate meter) that was not serialized, not calibrated

and had not been operationally*

checked, was found in use in the instrumentation

and controls laboratory.

Contrary to the above, on March 4, 1991, a Radeco air sampler (# 7241) was* fol.ind in room C-54 that had not been operationally

checked since February 16, * 1991. . Reason for Violation

1. Ludlum Model 177 (count rate meter) .Administrative

procedure

7.01, "Health Physics Portable Instrumentation

Program", Section 13.0. requires that all plant health physics portable instrumentation (HPPI) will be placed on a status board computer listing in accordance

with health physics procedure "Health Physics Instrument

Status Board". The purpose of this procedure

is to define the 9105080006

910429 PDR

05000255 Q PDR

-2 methods necessary

to maintain accurate status of the health physics instrumentation

and equipment.

The instrument

in question was not included in the HPPI program and therefore

was not controlled

in accordance

with the procedure.

The instrument

had been abandoned

by the Radiation

Safety Department

and was considered

obsolete.

However, the instrument

was *retained

in the Instrument

and Controls (I&C) laboratory.

The obsolete count rate meter was used by the I&C technicians

to perform checks for internal contamination

on disassembled

equipment.

It should be noted that all equipment

released to the I&C laboratory

for repair or calibration

is

by a qualified

radiation

safety technician

prior to its release in

with health physics

HP 7.15, "Contamination

Control".

The obsolete Ludlum 177 was a _redundant

meter not relied Upon for personal protection

nor was it used to perform and document a formal radiation

survey .. Furthermore, it should be nrited that I&C technicians not qualified

nor authorized

to perform contamination

surveys governed by HP 7.15; 2. Radeco Air Sampler Administrative

Procedure

7.01, "Health Physics Portable

Program", Section 6.1, requires that an operational

check of an instrument

_shall be perfofmed

at least once per day when the instrument .ii in use. A complete review of all air samples performed

between February 16, 1991 and March 4, 19_91 verified that the air sampler in question had been used only once during the that time period. Corrective

Actions Taken to Avoid Future Non-Compliance

1. The immediate

corrective

action was to remove the Ludlum 177 count rate meter from the I&C laboratory.

The Ludlum 177 has since been disposed of. This was considered

an isolated incident therefore

no further action is required.

2. A Radiological

Deficiency

Report (RDR) was initiated

because the health physics technician

using the air sampler failed to follow established

procedures

for checking out an instrument.

The health physics technician

did perform a daily operational

check of the instrument

but failed to document performance

of the check on the instrument

sticker as required by procedure.

Further corrective

action related to this incident included: . . . ' . -Counseling

the-involved

health physics technician

on the procedural

requirements

of

check out. -Sending a memo to all Radiation

Safety Department

personnel

reinforcing

adherence

to procedural

requirements.

A discussion

of technician

performance

issues at Radiation

Safety Department

meeting. In addition to the i_tems listed above, the contract technician

training course

• 3 will be reviewed to ensure that the HP instrument

control program requirements

are included.

Furthermore, this incident will be included in the Radiation

Safety Department

refueling

outage critique.

Date When Full

Will Be

Full tompliance

has been achieved with the exception

of the following

which will be completed

by December 1, 1991: -* review of the contract health physics training program with respect to instrument

control

-completion

of the Radiation

Safety Department

refueling

outage critique.

Violation

50-255/91006-03

10 CFR 50, Appendix B

VI requires that measures shall be established

to control the issuance of documents

which prescribe

all activities

affecting

quality. These measures

assure

documents, including

changes, are reviewed for adequacy and approved for release to authorized

personnel

and are distributed

to and used at the location where the prescribed

activity is performed.

Technical

Specification

6.8.1 requires that procedures

be established, implemented

and maintained.

• Administrative

Procedure

10.45, "Vendor Manual Control",

that vendor manuals be

approved for use, revisions

thereto and

controlled.

Contrary to the above, on March 7, 1991, numerous vendor manuals for portable health physics instrumentation, chemistry

instrumentation

and a component

for an installed

area radiation

monitor were found lacking the required level of controls specified

for such

Reason for Violation

The Palisades

vendor manual control program, Administrative

Procedure

10.45, "Vendor Manual Control" was implemented

following

the issuance of INPO Good Practice DE-102, entitled "Control of Vendor Manuals".

The definition

of vendor manuals in AP 10.45 Was derived from the definition

contained

in the INPO Good Practice.

Over the last five years -an extensive

effort has been directed

reviewing

and approving

vendor manuals associated

with installed

plant instruments

and equipment.

This position remains consistent

with past practice which was reiterated

in our response to Generic letter 90-03, dated September

28, 1990. Our response clearly stated our intention

to " ... ensure{s)

vendor manual information

appropriate

reviews and approvals

to insure its applicability

to installed

plant equipment." {emphasis

added) . It should be noted that an entirely separate program exists for the control of PTE and M&TE. This program is governed by NODS P07, "Control of Calibration . of Measuring

and Test Equipment", Admin. Procedures

5.07, "Control of Measuring

and Test Equipment, 4.21, "Chemistry

Program", 7.01, "Health