ML18043A220
| ML18043A220 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/05/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Youngdahl R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 7810130185 | |
| Download: ML18043A220 (4) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60137 Consumers Power Company ATTN:
Mr. R*. C. Youngdahl Senior Vice President 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
Thank you for the letter dated September 5, 1978, from Mr. David P. Hoffman, Assistant Nuclear Licensing Administrator, responding to our letter dated August 14, 1978, which transmitted a Notice of Violation and a copy of Investigation Report No.
50-255/78-16.
In your response you expressed disagreement with some items of noncompliance.
The following comments are made to clarify our position.
Item 1 - Infraction This item related to the creation of radiation levels in an unrestricted area, the Waste Storage Building, which, if an individual were continuously present in the area, could result in his receiving a dose in excess of 2 mR in any one hour.
In your response you state that:
(1) your plant health physics procedures include this area as part of the restricted area; (2) access is accomplished by passing through an open gate posted with a sign restricting access to authorized vehicles only, and; (3) 10 CFR 20.204(d) does not require control to such an area which is a high radiation area solely because of the presence of radioactive materials prepared for transport.
Regarding (1) above, the identification of the Waste Storage Building as a restricted area in your procedures does not make it a restricted area as defined in 10 CFR 20.3(a)(l4); i.e.,
"restricted area" means any area access to which* is controlled by the licensee for purposes of protecting individuals from exposure to radiation and radioactive materials.
Consumers Power Company ncr 5 rnm**
Regarding (2) above, the presence of a sign on the open gate is not considered a means of controlling access, especially since this gate was not being controlled so as not to impede the passage of construction contractor personnel through it. Additionally, access to the area could also be gained through an opening in the fence-line where a section had been removed at a location beyond the above-mentioned gate.
Regarding (3) above, 10 CFR 20.204(d) is contained within the section title "Same:
exceptions" and prefaced with "Notwithstanding the provisions of paragraph 20.203," that section preceding it entitled "Caution signs, labels, signals and controls." This section sets forth the requirements pertaining to the posting of radiation areas, high radiation areas and airborne radioactivity areas. It makes no reference to restricted are~s. Paragraph 20.204(d) does not, therefore, provide an exception to 20.105(b)(l).
In summary, the significance of this item of noncompliance is that persons other than radiation workers could have had undetected access to the building and received some exposure without your knowledge or permission.
The immediate action taken in this regard was verified during our tour of the plant on August 18, 1978.
Your long term corrective action will be reviewed during a future inspection.
Item 2 - Infraction This item related to the failure to perform an evaluation of extremity exposures.
This matter was discussed at the conclusion of our investigation on July 7, 1978 and no information was furnished that these evaluations had been made.
During our meeting on August 18, 1978 and in your response you stated that such evaluations were made and it was determined the whole body dose was the limiting factor rather than the extremity dose but no records of these evaluations were available.
Although not indicated in your response, we also learned during our August 18, 1978 meeting that an evaluation of hand exposures had been made since the con-clusion of our investigation.
This evaluation was reviewed by one of our inspectors at that time and no hand exposure problem was in-dicated by the results.
Further, it is our understanding that additional evaluations will be made.
Consumers Power Company 3 -
OCT 5 19/9 In view of the above, we will modify the item of noncompliance to the effect that records of these evaluations had not been maintained.
The noncompliance then becomes one relating to 20.40l(b) in that records were not maintained of surveys required by 10 CFR 20.20l(b).
This item is considered to be a deficiency rather than an infraction.
Item 3 - Deficiency This item related to the absence of required labeling of radioactive materials.
An exemption from the container labeling specified in Paragraph 20.203(f)(2) is provided by subparagraph 20.203(f)(3)(v) for containers in transport, as noted in your response.
- However, since the containers of concern were not in transport when observed during this inspection, the exception is not applicable and we still consider this to be an item of noncompliance.
Further we note that the reason for labeling containers, in addition to complying with Part 20 or USDOT requirements, is to alert individuals to the nature of the contents.
This purpose was not well served in that no labels were visible on the containers at the time of the inspection.
An exemption from specified labeling is also provided in subparagraph 20.203(f)(3)(vi) if access is limited to specified personnel, and if contents are known to such persons by a readily available written record.
Your corrective action of maintaining the building locked and fencing off the adjacent yard appears to meet the requirements of limiting access to this area.
This matter will be reviewed during a future inspection.
Item 4 - Infraction This item related to the failure to secure material against unauthor-ized removal.
Your response states that the Waste Storage Building has been locked and that shipping trailers are roped off and posted.
The roping off and posting by itself is not a sufficient means of securing material against unauthorized removal nor does it constitute sufficient control to meet the definition of a restricted area. It is our understanding, however, that in addition to the corrective action indicated, which we observed during our tour on August 18, any truck trailers containing radioactive materials in the future will be located within the area to be enclosed by rerouting the security fence as described in your response to item 1 above.
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Consumers Power Company OCT 5 1978 v1.ew of the size and ve1.ght of the conta1.ners, roping off the area around them is considered acceptable as a temporary expedient pending relocation of the aecurity fence.
This matter will be reviewed during a future inspection.
Item 5 - Infraction This item related to a failure to follow written operating procedures governing the chaages of filter.
We have no further questions on this item, and your corrective action will be reviewed during a future inspection.
In our August 18, 1978 letter we expressed concern about the nature and number of items of noncompliance and your not resolving problems having some impact on safety in a timely and effective manner.
We felt these matters were indicative of a breakdown in the management control of your radiation safety program.
Your response did not address this concern or indicate any action, taken or planned, which would improve your management control of the radiation safety program.
We again request that you address this subject in a letter to us.
Sincerely, James G. Keppler Director cc:
David P. Hoffman, Assistant Nuclear Licensing Administrator Mr. J. G. Lewis, Plant Superintendent
-Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission Myron M. Cherry, Chicago NRC Form 3188 (Rm) (l-78) NRCM 0240
- U.S. GOVERNMENT PRINTING OFFICE1 1078-253-817