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)

Text

GB Slade

• General Manager 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 PALISADES PLANT -

RESPONSE TO INSPECTION REPORT 91006; NOTICE OF VIOLATION 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 9~3, "Health Physics Instrument Status Board". The purpose of this procedure is to define the 9105080006 910429 PDR ADOC~ 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 sur~eyed by a qualified radiation safety technician prior to its release in a~cordance with health physics procedur~ 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 ar~ not qualified nor authorized to perform contamination surveys governed by HP 7.15;

2. Radeco Air Sampler Administrative Procedure 7.01, "Health Physics Portable Inst~umentation 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 instfu~ent 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 Compli~nce Will Be Achiev~d 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 issue~.

- completion of the Radiation Safety Department refueling outage critique.

Violation 50-255/91006-03 10 CFR 50, Appendix B Crit~rion VI requires that measures shall be established to control the issuance of documents which prescribe all activities affecting quality. These measures sh~ll assure th~t 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", requ~res that vendor manuals be identifi~d, approved for use, revisions thereto and distributi~n 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 docu~ents.

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 t~ward 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 ~eceives 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