ML18344A180

Responding to Inspection Report 50-255/98009, Which Recommended Broad Examination of Radiological Protection Program. Advising of Instituted Corrective Actions & Management Is Continuing to Positively Reinforce

ML18344A180
Person / Time
Site:	Palisades
Issue date:	07/24/1998
From:	Rogers D Consumers Energy Co, (Formerly Consumers Power Co)
To:	Office of Nuclear Reactor Regulation
References
IR 1998009
Download: ML18344A180 (3)

Text

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Consumers Energy 4>

A CMS Energy Company Palisades Nuclear Plant Darld llC Rogers 21780 Blue Star Memorial Highway General Manager

• Plant Operations Covert, Ml 49043 July 24, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT HEPLY TO COVER LETTER CONCERNS FROM INSPECTION REPORT 50-255/98009 The purpose of this letter is to respond to the statements in the body of the cover letter of Inspection Report 50-255/98009(DRS). In that letter, you recommended that we*

perform a broad examination of the implementation of our radiological protection program.

In the fall of 1997 we had identified several examples where we failed to effectively control high radiation area boundaries and communicate radiological conditions. Based on these issues, we took significant action to communicate expectations to station personnel and to improve the effectiveness of supervisory monitoring. These actions proved partially effective, in that we saw a significant improvement in performance including an increased sensitivity for problem identification and questioning attitudes.

As a separate matter, in the fall of 1997, we also set much more aggressive dose targets for the 1998 refueling outage and significantly increased our ALARA planning efforts.

As a result, in the 1998 refueling outage, we achieved our best refueling outage dose performance with a total dose of 190 person-rem, which was a 23% improvement over

. the 1996 refueling outage. O~r Committed Effective Dose Equivalent dose for the 1998 refueling outage was 1.851 person-rem vice 2.926 person-rem for the 1996 refueling outage. The assigned skin dose of 5.900 person-rem was much lower than the 9.223 .

.Ci (/Ji { . , , .. I f', /

2 person-rem assigned during the 1996 refueling outage. ALARA pre-job planning and preparation were substantially improved over the 1996 refueling outage. There were other improvements in our Radiation Protection Program imp.lementation that were achieved as well, and are. noted in the Inspection Report.

Notwithstanding the improved results above, there were too many instances where communication and coordination between work groups and performance of radworkers and HP Technicians fell well short of our expectations indicating that improvement opportunities exist in our program's implementation, especially in the area of contract personnel. We were very disappointed with these performance lapses in our Radiation Protection Program .

. As a result, a multi-disciplinary review team was formed to evaluate the events which occurred during the refueling outage. This. team was tasked with performing a common cause analysis, determining root causes and reviewing past corrective actions to determine effectiveness. An outside expert in Radiation Protection was brought in as a member of the team. Bench marking visits were also made to two other nuclear plants to validate the team's proposed corrective actions. The results of this effort determined that, for the events which occurred during the 1998 refueling outage, management expectations were not clearly communicated or understood by all contract employees in the areas of job preparation, use of written instructions and radiological work coverage.

In addition, adequate defenses were not .always in place for radiologically significant evolutions.

• Previous corrective actions to address high radiation posting violations focused on increasing sensitivity and awareness of radiological requirements to Plant HP Technicians and radworkers. However, these actions were not broad enough in that they did not adequately communicate expectations to contract workers.

To address these issues with the implementation of the Radiation Protection Program, the following actions have been completed:

1. Management expectations for job preparation, use of written instructions and radiological work coverage have been clearly communicated to Plant Radiological Services staff.

2. . Defenses for critical radiological evolutions have been strengthened. This includes the requirement for double verification of all locked Ra.diation Controlled Doors:

. 3. Critical monitoring, coaching and assessing activities have been instituted to gauge

• the effectiveness of these actions .

• In addition, prior to the start of the f999 refueling outage, significant actions will be taken to ensure contract workers understan.d and comply with our expectations.

• Management expectations for job preparation, use of written instructions and .*

3 radiological work coverage will be clearly communicated to contract HP Technicians:

Increased management field observations and monitoring will be instituted during the*

1999 refueling outage to ensure these expectations are met. Also, to mor.e clearly communicate expectations to refueling personnel, the Refueling Manual will be revised to include radiological controls.

In summary, Consumers Energy has examined the events which led to the violations cited in Inspection Report 50-255/98009 from a broad programmatic perspective to determine implications to the Radiation Protection Program implementation at Palisades. We have identified several areas where the program can be strengthened, particularly in the communicaUon of management expectations for iadiation woiker practices, espedally to contract personnel and have instituted corrective actions. As a final note, it is important to recognize that the deviations which led to the violations were identified by station radiation protection personnel.. Management is continuing to positively reinforce this questioning attitude and lower the threshold for problem identification by our personnel and expect this desired human performance to play an important role in meeting our Radiation Protection Program objectives.

Should you have any questions regarding this matter, please contact this office.

David W. Rogers General Manager - Plant Operations CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades *

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