ML19242B334
| ML19242B334 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/27/1979 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19242B330 | List: |
| References | |
| NUDOCS 7908080107 | |
| Download: ML19242B334 (3) | |
Text
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Consun1ers Power Company General Of fic es 212 West Mshigan A venue. Jac mson, M.c hegan 49201
- Area Code S17 7H H-05 SO
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C June 27, 1979 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - IE INSPECTION REPORT 79-06 Consumers Power Company's response to the alleged discrepancies noted in IE Inspection Report 79-06 dated June 6, 1979 is as follows:
Item 1 - Infraction 10 CFR 20.203(c)(2) requires that high radiation areas, other than HRAs established for thirty days or less, be equipped with control devices which alarm or reduce radiation levels upon entry or be maintained locked with positive sontrol over entries.
Contrary to the above, sever high rai.ation areas, including the clean vaste receiver tank pump room, the, ronomete room, the spent resin storage tank room and the volmne control and radwaste demineralizer rooms, were not locked or equipped with control devices during inspections on March 21 or March 28.
Additionally, positive control has not been exercised over entries to these and other locked HRAs as exhibited by the failure to routinely follow the HRA access controls specified in Procedure HP 2.16 and the failure to exercise positive control over HRA keys.
Response
Discussion / Evaluation:
10 CFR 20.203(c)5 permits licensees to apply to the Commissien for approval of alternate methods of controlling ~, entry into high radiation areas.
On October 4, 1978, the Palisades Flant On-Site Review Committee (PRC) reviewed and recommended for approval a proposed change to the Palisades Technical Specifications which would have provided an alternate method of controlling access to high radiation areas.
This alt'ernate method was similar to the method provided in the model Technical Specifications.
Because of administrative oversights, this proposed change was not processed further at that time.
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In our December 8, 1978 res to items of noncompliance contained in IE Inspection Report 78-26,(1)ponse Consumers Power Company alluded (albeit in general terms) to new methods of high radiation area entry controls in discussing the Limited Radiation Area Access (LRAA) program.
As stated in the December 8, 1978 submittal, the target date for implementing the LRAA program was January 1, 1979.
In attempting to satisfy the commitment to meet the January 2, 1979 deadline for implementation of the LRAA program, the revised high radiation area entry controis methods were put into effect without specific NRC approval.
This departure from the requirements of 10 CFR 203(c)(2) was not willful, but rather was caused by administrative oversights as explaiaed above.
Correctire Action Taken and Results Achieved The method of controlling entry into high radiation areas has been returned to that specified by 10 CFR 20.203(c)(2).
As provided by 10 CFR 20.203, Consumers Power Company applied for(2) and received permission from the commission (3) to use an alternate method for controlling entry into high radiation areas (Palisades Plant Technical Specification Amendment No 48, dated May 15, 1979).
A letter strescing the importance of key control has been sent to all Health Physics Supervisors and Technicians and to all Shift Superviscrs.
This memorandum will also be raviewed during "fifth shift" training for operators.
Corrective Action To Be Taken To Avoid Further Nontempliance failure to exercise positive controls over high radiation area keys has been a continuing problem caused by a number of factors, among which is the condition that three separate series of locksets and keys are used throughout the plant.
A new set of locks and keys to replace all existing locks and keys to high radiation area doors has been orde ed.
Elimination of multiple keys is expected to eliminate much of the administrative burden in key cor;rc l. and, thereby, enhance the key control program.
Date When Full Compliance Will Be Achieved With respect to high radiation area entry controls, Palisades is in compliance with 10 CFR 20.203(c)(2).
The keys and locks referred to above are expected to be on site and installed not later than September 15, 1970 (1)D P Hoe iman to J G Keppler, 12/8/78.
(2)D P Hof fman to D L Ziemann, 4/23/79.
(3)D ( Ziemann to D A Bixel, 5/15/79.
ocCo79-0540a-43 JOJ
3 Item 2 - Infraction Technical Specifications 6.8.1 and 6.11.1 require that certain procedures, including radiation protection and radiation instrument calibration, be implemented and adhered to.
Contrary to the above, significant discrepancies in the implementation of Procedures HP 2.1 (Daily Instrument Checks), HP 2.12 (Surveys), HP2.16 (HRA Controls), HP 2.18 (Instrument Status Board) and HP2.26 (Instrument Calibrations) were identified during this inspection.
Response
Corrective Action Taken and Results Achieved and Correction Action To Be Taken To Prevent Furthe r Noncompliance HP 2.1 (Daily Instru.nent Checks) - Procedures have been revised tc require the use of a saparate check sheet for instrument checks.
Only out of specification conditions will be noted in the radiation protection log.
HP 2.12 (Surveys) - The procedures governing performance of weekly and monthly surveys are being reviewed for poss'.ble deletion.
Past survey results indicate that no significant problems have been identified in areas covered by the weekly and monthly surveys.
HP 2.16 (HRA Controls) - Discrepancies and corrective action related to high radiation area controls have been discussed in Item 1 above.
HP 2.18 (Instrument Status Board) - The instrument status board has been updated to properly reflect instrument calibration status.
A procedural requirement to periodically review the board will be enforced.
HP 2.26 (Instrument Calibrations) - The procedures related to instrument calibrations have been thoroughly reviewed and will be revised to ensure conformity throughout.
Date When Full Compliance Will Be Achieved T'ie actions described above will be completed prior to July 31, 1979.
David P Hoffman (Signed)
David P Hoffman Assistant Nuclear Licensing Administrator CC Director, Of fice cf Nuclear Reactor Regulation Director, Office of Inspection and Enforcement oc0679-0540a-43 G J
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