ML18064A848

Responds to Violation Noted in Insp Rept 50-255/95-07 on 950413-0527.Corrective Actions:Air Sampling Portion of REMP Now Being Completed by Plant Radiological Svcs Dept & HP Procedure 10.10 Will Be Revised

ML18064A848
Person / Time
Site:	Palisades
Issue date:	07/27/1995
From:	Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9508010057
Download: ML18064A848 (4)

Text

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KurtM. Haas Plant Safety and Licensing Director Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, _Covert, Ml 49043 July.27, 1995 U S Nuclear Regulatory Commission Document Control Desk

• Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT _

REPLY TO NOTICE OF VIOLATION - SAMPLING DEFICIENCIES IN RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NRC Inspection Report No. 50-255/95007(DRP) contained a Notice of Violation for a Severity Level IV Violation involving the failure to correct sampling deficiencies in the Radiological Environmental Monitoring Program. Attachment 1 contains our response to the vi6lation.

SUMMARY

OF COMMITMENTS This letter contains four new commitments.

I. The deficient air sample techniques used by the contractor will be evaluated to determine the validity of past air sample .results.

2. Health Physics Procedure 10.10; "Pali sades Radiological Environmental Program Sample Collection and Ship~ent" will be revised to intorporat~

clear expectations for air sampling.

3. The Radiological Services Department sample collectors will.be trained on the revised sampling procedures~ * -

4. As part of the Radiological Services Department's self assessment program, annual self assessments will be performed on the environmental monitoring program.

• IKurt M. Haas Plant Safety and Licensing Director CC Administrator, Region III, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades

• Attachment 9508010057 950727 PDR ADOCK 05000255 Q PDR A CMS' ENERGY COMPANY fff/t

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ATIACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION SAMPLING DEFICIENCIES IN RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2 Pages

REPLY TO NOTICE OF VIOLATION SAMPLING DEFICIENCIES IN RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

'NRC VIOLATION During an'NRC inspection conducted from Apri1 13 through Hay 27, 1995, a.

violation of NRC requirements was identified.

• In accordance with the "Genera]

Statement of Po1icy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the vio1ati0n is 1isted be1ow:

• Technical Specification 6.8.4.b and 6.5.2.4.2.j respectively require a program to monitor the radiation and radionuc1ides of the Pa1isades Nuclear P1ant and audits of the radio1ogica1 environmental monitoring program. 10 CFR 50 Appendix 8 Criterion XVI requires that identified deficiencies be promptly identified and corrected.

Contrary to the above, sampling deficiencies in the radio1ogica1 environmental monitoring program remained uncorrected after being identified by the Nuclear Performance Assessment Department in October 1991 and October 1992.

This is a Severity Leve1 IV violation .. (Supplement IV)

CONSUMERS POWER COMPANY RESPONSE Background.

Plant review of the event confirmed that past Nuclear Performance Assessment Department (NPAD) audits as far back. as 1990 had identified similar problems with inadequate sampling techniques. Following the 1990 NPAD audit, NPAD reconvnended replacing the local sampling contractor by performing the sampling in-house. Discussions with four Radiological Environmental Monitoring Program (REHP) supervisors indicated that they all had discussed proper sampling techniques with the contractor. Three of the past REMP supervisors stated that they had recommended the replacement of the local sampling contractor.

Recommendations to terminate the local sampling contractor were not approved by plant management due to factors other than job performance. These other factors included concerns with convnunity relations coupled with a de$ire to maintain local residents employed at the plant. The local sampling contractor -

was a local conununity leader and had held this and similar jobs for many years with the plant *. The management decisions to retain the same contractor to obtain the samples was based on the thought that, once properly trained, the local sampling contractor could meet the sampling expectations:

However, NPAD audits in 1991 and 1992 continued to show various problems with the way that samples were taken. As a follow-up to these audits, the contractor received training aimed at improving performance for the issues identified during the audits.

2 NPA!r audits from late 1993 found no deficiencies with the sampling program, which may have given plant management the feedback that the contractor .

sampling training goals had been met. However, investigations completed as a result of the identification of the recent performance issues determined that a relative of the normal local sampling contractor, with the same initialS as the normal contractor, was actually observed taking the samples during the 1993 audit. Based on the most recent occurrences, it is evident that observed.

improvement in performance was short-lived and. was not attributable to the local sample collector normally performing the work.

Reason for the Violation The reason for the violation was a plant management decision to correct the sampling performance deficiencies by retraining and surveillance of the local sampling contractor, rather than by replacing the contractor. A contributing factor was also a failure to identify that the 1993 audit findings did not represent a program improvement base.d on who was actually performing the sampling.

• Corrective Steps Taken and Results Achieved The air sampling portion of the REMP program is now being completed by the plant Radiological Services Department. REMP program supervisors, as part of their supervision responsibilities, will be monitoring the field sampling activities. The balance of the en~ironmental sampling program was looked at and no other problems were identified with the sampling service.

Based on discussions *with individuals involved with administering contractors and contracts for the plant, .this has been determined to be an isolated event.

The deficient air sampling techniques used by the local sampling contractor will be evaluated to determine the validity of past air sample results.

As part of the Radiological Services Department's self-assessment program, annual self-assessments will be performed on the environmental monitoring program.

Corrective Steps Taken to Avoid further Violations Heal~h Physics Procedure 10.10, uPalisades Radiological Environmental Program Sample Collection and Shipment," will be revised to clarify expectations for air sampling.

The Radiologic*l Services D~partment sample collectori will be trained on the revised sampling procedures.

Date When Full Compliance Will Be Achieved full compliance has been achieved with reassignment of the air sampling program to the Radiological Services Department.