ML18057A879
| 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
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