ML18046A348
| ML18046A348 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/28/1980 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18046A349 | List: |
| References | |
| NUDOCS 8101300351 | |
| Download: ML18046A348 (4) | |
See also: IR 05000255/1980014
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION Ill
Docket No. 50-255
Consumers Power Company
ATTN:
Mr. R. B. DeWitt
Vice President
Nuclear Operations
212 West Michigan Avenue
Jackson, MI
49201
Gentlemen:
799 ROOSEVELT ROAD
GLEN ELLYN, ILLINOIS 60137
NG\\I 2 8 1980
Subject:
Health Physics Appraisal
The NRC has identified a need for licensees to strengthen the health
physics programs at nuclear power plants and has undertaken a signif-
icant effort to ensure that action is taken in this regard.
As a
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first step in this effort, the Office of Inspection and Enforcement is
conducting special team appraisals of the health physics programs, in-
cluding the health physics aspects of radioactive waste management and
onsite emergency preparedness, at all operating power reactor sites.
The objectives of these appraisals are to evaluate the overall adequacy
and effectiveness of the health physics program at each site and to
identify areas of weakness that need to be strengthened.
We will use
the findings from these appraisals as a basis not only for requesting
individual licensee action to correct deficiencies and effect improve-
ments but also to improve NRC requirements and guidance.
This effort
was identified to you in a letter dated January 22, 1980, from
Mr. Victor Stello, Jr., Director, NRC Office of Inspection and Enforcement.
During the period August 4 to August 15, 1980, the NRC conducted the
special appraisal of the health physics program at the Palisades Nuclear
Plant.
Areas examined during this appraisal are described in the enclosed
report (50-255/80-14).
Within these areas, the appraisal team reviewed
selected procedures and representative records, observed work practices,
interviewed personnel, and performed independent measurements.
We request
that you carefully review the findings of this report for consideration
in improving your health physics program.
Findings of this appraisal indicate that several significant weaknesses
exist in you*r health physics program.
These include, qualifications,
training, procedures, quality assurance, instrumentation, ALARA, and
airborne release quantifications.
These items are set forth in Appendix
. SlG 1300 35\\
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Consumers. Power Company
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NOV 2 8 1980
A, "Significant Appraisal Findings." Your past performance in personal
exposure and radiological effluent controls has been acceptable but we
believe that the identified weaknesses require correction to enable you
to perform equally well in future normal and offnormal situations.
Your present health physics program is considered adequate to support
continued operation while achieving acceptable correctiv~ action for
the identified weaknesses.
We recognize that an explicit regulatory requirement pertaining to each
significant weakness identified in Appendix A may not currently exist.
However, to determine whether adequate protection will be provided for
the health and safety of workers and the public, you are requested to
submit a written statement within twenty (20) days of your receipt of
this letter, describing your corrective action for each significant weak-
ness identified in Appendix A, including:
(1) steps which have been taken;
(2) steps which will be taken; and (3) a schedule for completion of action.
This request is made pursuant to Section 50.54(f) of Part 50, Title 10,
Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities do
not appear to have been conducted in full compliance with NRC requirements,
as set forth in the Notice of Violation enclosed as Appendix B.
The items
of noncompliance in Appendix B have been categorized into the levels of
severity as described in our Criteria for Enforcement Action dated December
13, 1974.
Section 2.201 of Part 2, Title 10, Code of Federal Regulations,
requires you to submit to this office, within twenty (20) days of your
receipt of this notice, a written statement or explanation in reply, in-
cluding:
(1) corrective steps which have been taken and the results *
achieved; (2) corrective steps which will be taken to avoid further items
of noncompliance; and (3) the date when full compliance will be achieved.
You should be aware that the next step in the NRC effort to strengthen
health physics programs at nuclear power plants will be a requirement
by the Office of Nuclear Reactor Regulation (NRR) that each licensee
develop, submit to the NRC for approval, and implement a Radiation Pro-
tection Plan.
Each licensee will be expected to include in the Radiation
Protection Plan sufficient measures to provide lasting corrective action
for significant weaknesses identified during the special appraisal of the
current health physics program.
Guidance for the development of this plan
will incorporate pertinent findings from all special appraisals and will be
issued for public comment before the end of this calendar year.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter, the enclosures,
and your response to this letter will be placed in the NRC's Public Document
Room.
If this material contains any information that you believe to be
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Consumers Power Company
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h* . ..; ~
proprietary, it is necessary that you make a written application within 20
days to this office to withhold such information from public disclosure.
Any such application must be accompanied by an affidavit, executed by the
owner of the information, which identifies the document or part sought to
be withheld and which contains a statement of reasons which addresses with
specificity the items which will be considered by the Commission as listed
in Subparagraph (B)(4) of Section 2.790.
The information sought to be with-
held shall be incorporated as far as possible into a separate part of the
If we do not hear from you in this regard within the specified
period, this letter and the enclosures will be placed in the Public Docu-
ment Room.
We will gladly discuss any questions you have concerning this inspection.
sincerely,
Enclosures:
1.
Appendix A, Significant
Appraisal Findings
2.
Appendix B, Notice of
Violation
3.
IE Inspection Report
No. 50-255/80-14
cc w/encls:
Mr. D. P. Hoffman, Nuclear
Licensing Administrator
Mr. R. W. Montross, Manager
Central Files
Reproduction Unit NRC 20b
Local PDR
vJames G.
.,
Director
Ronald Callen, Michigan Public
Service Commission
Keppler
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Appendix A
SIGNIFICANT APPRAISAL FINDINGS
Consumers Power Company
License No. DPR-20
Based on the Health Physics Appraisal conducted August 4-15, 1980, the
following items appear to require corrective action.
(Section references
are to the Details portion of the enclosed report.)
1.
A documented C&RP qualification program is needed to ensure that
personnel are properly assigned work responsibilities.
The program
should be formalized to incorporate qualification prerequisites from,
among others, ANSI Nl8.l-1971 (ANS 3.1-1978), Regulatory Guide 1.8,
and the March 15, 1977, NRR letter regarding shift radiation protection
procedure qualification criteria.
Shift coverage must be adequate to
ensure that necessary samples and measurements can be taken in accident
situations to promptly evaluate radiation hazards and effect appro-
priate radiation precautions.
(Sections 3.a and 3.b)
2.
The training program requires significant improvement in terms of
actual training provided and documentation of training needs and
progress.
(Sections 4.a, 4.c, and 13)
3.
The quality assurance program needs to be upgraded in the areas of
deviation reporting and effectiveness of corrective actions. (Section
5)
4.
Procedural coverage and adherence need upgrading to include activities
not presently addressed and to resolve inconsistencies between proce-
dures and actual practices.
(Sections 3.a and 6)
5.
The instrumentation program needs upgrading to ensure adequate beta
measurements, operable survey instruments, calibrated high range
survey instruments, an adequate supply of CAM's to evaluate changes
in airborne radioactive concentrations, and effective monitoring of
personal contamination.
(Sections 9.a, 9.b, 9.c, and 9.d)
6.
The ALARA program requires significant improvement, including:
formalized structure and guidance, job specific dose records and
evaluation, and development of specific goals.
(Section 10)
7.
Airborne effluent controls require improved quantification of gaseous
releases, using both the normal and high range stack monitors, includ-
ing:
operating procedures, training, record clarity, monitor energy
response, and readout availability.
(Sections 9.f and 11)