ML18054A529
| ML18054A529 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/02/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8902070125 | |
| Download: ML18054A529 (3) | |
Text
consumers
-Power PllWERIN&
llllUllliAN9S PIUlliRESS **
General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 February 2, 1989
- Nuclear Regulatory Commission Document Control Desk Washington, DC
- 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO NOTICE OF VIOLATION PRESENTED IN IE INSPECTION REPORT 88021 Kenneth W Berry Director Nuclear Licensing NRC Inspection Report 50-255/88-021 dated January 3, 1989 transmitted one notice of violation.and requested Consumers Power Company provide a. written response.
The requested response is as follows:
Notice Of Vi~l~tion (DPR 50-255/88021)
As a result of the inspection conducted during the period of September 6 through December 8, 1988, and in accordance with 10 CFR Part 2, Appendix C -
General Statement of Policy and Procedure for NRC Enforcement Actions (1988),
the following violation was identified:
Technical Specification 6.12.2 requires locked doors be provided to prevent*
unauthorized entry into each high radiation area in which the radiation level is greater than 1000 mR/hour.
Contrary to the above, on June 10, September 30 and Decembe.r 17, 1987 and on September 5 and 7, 1988 locked doors were not provided to prevent unauthorized entry.into certain high radiation areas in which the radiation levels were greater than 1000 mR/hour.
This is Severity Level IV violation.
Corrective Actions Taken And Resu],ts Achieved Palisades Technical Specification 6.12.2 requires that locked doors be provided to prevent unauthorized entr.y into areas where general area radiation fields exceed 1000 mR/hour.
Additionally, it is required that keys allowing access to these areas be maintained under the administrative control of the OC0289-0033-NL04
I Nuclear Regulatory Commission Palisades Plant Response to Inspection Report 88021 February 2, 1989 Shift Supervisor on-duty and/or the Plant Health Physicist. Administrative control over lR keys is established by maintaining them within a key locker under control of the on-duty lead Radiation Safety Technician and within the Shift Supervisor Controlled Key Cabinet.
Use of the key under control of the Shift Supervisor is intended to be for emergency use only.
Health Physics Procedure 2.5, "Entry Control For High Radiation Areas Over lR/hr" sets forth procedural requirements for entries into areas where the general radiation level exceeds lR/hr.
As presented in the inspection report, the instances cited which occurred in 1987 can be-partially attributed to mechanical problems, however, the root cause of all five events has been attributed-to inadequate personnel perfor-
- mance.
Those individuals identified as responsible for failing to assure lR doors were locked upon exiting the area have been counseled as to the sig-nificanc-e of the failure.
All Radiation Safety Technicians have been trained as to the importance of maintaining control of lR door keys and the lR door key log.
Tighter controls have been implemented for the storage and use of lR door keys.
A new key locker has been installed in the Radiation Safety Office.
This locker provides a separate locked area for the storage of lR door keys.
The key for this compartment is controlled by the Lead Radiation Safety Technician on-duty.
At shift change, all keys are inventoried and the key providing access to the lR door keys is personally transferred to the on-coming lead technician.
Corrective Actions To Be Taken To Avoid Further Non-Compliance All lR door keys are being inventoried and accounted for to assure no stray/lost keys exist. If it is determined that lost or missing keys exist, the existing lR door locks and keys will be changed to ensure no unauthorized use of keys occurs.
2 A program is being developed to provide secondary independent verification that lR doors accessed have been locked.
The effectiveness of this program will be reviewed and its continued need re-evaluated at the end of 1989.
This secondary verification will be provided within a timely manner so that doors found open during this verification will be secured promptly so no Technical Specification violations occur.
A Management Review Board with the Plant General Manager in attendance will be held with any individual identified to have failed to properly secure a lR door.
The board will provide a review of the incident and senior Plant management involvement in determining appropriate corrective action
- OC0289-0033-NL04
Nuclear Regulatory Commission Palisades Plant Response to Inspection Report 88021 February 2, 1989 Date When Full Compliance Will Be Achieved Inventory of the lR door keys will be completed by February 15~ 1989. If lR door lock change-out is warranted, it will be completed by April 30,.1989.
The secondary verification program will be implemented by February 28, 1989.
Evaluation of the effectiveness of this program will be completed by the end of 1989.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC0289-0033-NL04 3