ML17328B082
| ML17328B082 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/20/1990 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML17328B083 | List: |
| References | |
| NUDOCS 9008020030 | |
| Download: ML17328B082 (8) | |
See also: IR 05000255/1990013
Text
Docket No. 50-255
Consumers
Power
Company
ATTN:
David P.
Hoffman
lice President
Nuclear Operations
1945 West Parna11
Road
Jackson,
NI
49201
Gentlemen:
This refers to the special
team assessment
conducted
by Hr.
C.
F. Gill and
other
NRC and contractor
personnel
on Yiay 13-31,
1990, of activities at the
Palisades
Nuclear Generating
Plant authorized
by
NRC Provisional Operating
License
No.
DPR-20 and to the discussion of our findings with you and others
of your staff at the conclusion of the inspection.
The assessment
was conducted
to evaluate
the effectiveness
of licensee
actions
to keep radiation
doses
at the Palisades
Plant
as
low as reasonably
achievable
(ALARA).
The historically high collective radiation
dose
incurred at the
Palisades
Plant prompted this assessment.
The team used selective
examinations
of procedures
ard representative
records,
interviews with personnel,
independent
measurements
and observations
of activities in progress
to perform the
evaluation.
Within the scope of the assessment,
no violations or deviations
were identified.
However,
a number of weaknesses,
which are discussed
in detail in the enclosed
report,
were identified which 'in our view contributed to'your historically
high radiation
dose at Palisades.
During our meeting
on July 18,
1990,
you
described
actions that you have initiated to address
many of these identified
weaknesses.
Ve also are
aware that you are conducting your own self
assessment
of your health physics
program.
As we discussed,
after you have
completed your evaluation of this report
and after completion of your
self-assessment,
we would like to meet with you again to discuss
the progress
of improvements
in your health physics/ALARA programs.
We will contact you
to set
up the meeting in early September.
In accordance
with 10 CFR 2.790 of the Commission's
regulations,
a copy of this
letter and its enclosures will be placed in the
NRC Public Document
Room.
-0
Consumers
power
Company
JUL 2
0
1990
u have concerning this assessment.
Me will gladly discuss
any questions
you have
Sincer ely,
Enclosures:
l.
Executive
Summary
2.
NRC Inspection
Report
No.
50"255/90013(DRSS)
cc w/enclosures:
Mr. Kenneth
M. Berry, Director
Nuclear Licensing
Gerald
B. Slade,
General
Manager
DCD/DCB (RIDS)
Licensing
Fee
Management
Branch
Resident
Inspector, RIII
James
R. Padgett,
Michigan Pub1ic
Service
Commission
Michigan Department of
Public Health
bcc:
,R.
R. Bellamy,
NRC RI
D.
M. Collins,
NRC RII
B. Murray',
NRC RIV
G.
P.
Yuhas,
NRC
RV
C.
S.
Hinson,
NRR,
PRPB
T.
F.
Dragoun,
NRC RI
L.
L, Coblentz,
NRC
RV
B.
T. Dionne,
J.
Baum,
R.
E. Utting,
AECB
Charles
E, Norelius, Director
Division of Radiation Safety
and Safeguards
RIII ~
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Burgess
Enclosure
1
EXECUTIVE SUMMARY
In 1988 the annual collective radiation
dose at the Palisades
Nuclear
Generating
Plant
was
more than twice the'national
average for Pressurized
Water Reactors
(PWRs),
Including 1988, the Palisades
plant was above the
U.S.
PWR average
dose for 10 of .the last
13 years.
A special
radiological
team inspection
conducted at Palisades
during late
1988 (Inspection
Report
No. 50-255/88021(DRSS))
concluded that although the licensee
incurred
much of
the
1988 radiation exposure
on unanticipated
outage
work and
on unusually
extensive
or one-time modification/maintenance .activities, work planning
deficiencies
appeared
to have contributed to the high dose.
Also, because
of
initial poor plant system design
and previous
poor operational
and maintenance
activities, the plant had
been
plagued with hot spots
and relatively high
general
area radiation fields which impacted the dose.
It was also concluded
that although the licensee
had implemented
a radiation source
reduction
program three years before,,it
had not been
as effective as anticipated
and
that much additional effort appeared
necessary
to adequately
reduce
personnel
exposures
At a meeting with NRC regional
management
on December 8, 1988, the
licensee
indicated,
in part, that planned
improvements
in the
ALARA program
were expected
to significantly improve future dose
saving efforts.
The collective dose for Palisades
declined
from 730 person-rem in 1988 to
294 person-rem
in 1989.
This value is expected
to be about the
same
as the
national
average for PWRs;
however,
the lack of a Palisades
refueling outage
in 1989 significantly contributed to the decline in annual 'collective dose.
The annual
dose
goal for 1990 at Palisades
was established
at about
1200 person-rem
which includes
about
700 person-rem allotted for the Fall
replacement
project
(SGRP).
Because
of past high dose
expenditure
and the high-dose jobs anticipated
during the Fall
1990
SGRP/
refueling outage,
the
NRC concluded it was appropriate
to conduct another
special
review of the Palisades
ALARA program.
During the period of May 13-31,
1990,
a special
team assessment
was conducted
by the
NRC to evaluate
the licensee's
efforts for maintaining occupational
radiation
doses
as
low as reasonably
achievable
(ALARA).
The assessment
included
a review of the causes
of the past high radiation doses;
an evaluation
of the licensee's
current organization
and program for keeping radiation
doses
ALARA; a review of past
and current licensee initiatives to bring the radiation
doses
to within industry norms;
and
an evaluation of licensee
management's
awareness
of, involvement in, and support for the
ALARA program.
The team identified ALARA program weaknesses
which indicate that
a broadscope,
proactive
ALARA implementation
improvement plan should
be initiated by the
licensee.
The identified weaknesses
included:
Although the team noted that management
support of the 'ALARA program was
evident through
such mechanisms
as the Scope Control
Team and the
Committee,
the lack of an overall management-directed
ALARA improvement
plan appeared
to contribute
toward inconsistent
levels of ALARA
awareness
and differing levels of involvement in ALARA initiatives among
various station groups.
~ 1I
1
Enclosure
1
ALARA considerations
were not well integrated into work planning
activities.
Veak procedures
governing
ALARA activities appeared
indicative of a lack
of firm ALARA commitment.
Mith.some notable exceptions,
there
appeared
to be
a cultural attitude
that
ALARA activities
and concerns
were solely the responsibility of the
Radiological
Services
Department
(RSD).
ALARA concepts
have not been fully incorporated into the training
program,
including general
worker and radiological safety technician
training lesson
plans
and procedures.
In addition to the above concerns,
the
team
had cohcerns
regarding the
RP/ALARA
readiness
for the steam generator
replacement
project (SGRP)/refueling
outage
scheduled for mid-September
1990.
The inspectors
concluded that not only
would the licensee
have difficulty in significantly improving the plant ALARA
program before
the
SGRP, but the licensee
might also
have difficulty in
adequately
addressing
the following ALARA concerns
before the outage.
The. licensee
had not developed corrective action assignments
and schedules
to resolve internal
recommendations
and lessons
learned
from the
1988
refueling outage.
The licensee's
self assessment
of the
RP/ALARA program,
begun in
February
1990, is not scheduled for completion unti l August
1990.
corrective actions
had not been
assigned
and scheduled for implementation
during the Fall
1990 outage.
RP/ALARA organizational
structure,
assignments,
duties,
responsibilities,
authority and interface with the plant
RP/ALARA
organization
had not been determined.
Numerous similar projects at other
facilities had delineated
these organizational/managerial
functions
much
earlier in the planning stage.
Subsequent
to the team inspection,
the licensee
informed Region III that
an
implementation
plan to ensure
RP/ALARA readiness
for the Fall
1990
SGRP/refueling
outage,
hs well as
a long-term improvement plan,
has
been
developed.
A meeting is scheduled
on July 18, 1990, to determine
RP/ALARA
readiness
for the Fall,1990 outage.
Several
program strengths
were also identified and are
summarized
as follows:
Dose savings
have ',been
achieved for certain repetitive high-dose jobs.
Superintendents
ha've
been involved in setting
annual
dose goals for 1990
and
have established
additional "exceptional" target levels.
The quality of post-job
ALARA reviews
has
been
good.
ri
Enclosure I
'he
ALARA staff is proactive
and conscientious.
The ALARA/refueling
engineering
interface
appears
to be working well.
Also, the assignment
of some
RWP/ALARA personnel
to various project work groups to expedite
RMP preparation
and
ALARA reviews appears
to be
a positive initiative.
Use of the Five-Year Plan for planning long-term, large-capital
initiatives has
been beneficial.
Improved design
and electro-polishing of new steam generators
is
indicative of positive actions to reduce future dose.
The surrogate
tour system is
a useful training and familiarization tool.
Contractor fees
have
been tied to
ALARA performance.
Further monetary
incentives
have
been
developed
to elicit worker ALARA suggestions
and to
induce department
managers
to meet annual
department
ALARA goals.
A comprehensive
self assessment
of the
ALARA program is underway.
A more detailed listing of both strengths
and improvement
items are set forth
in each section of the report details.