ML20030C140
| ML20030C140 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/30/1981 |
| From: | Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20030C135 | List: |
| References | |
| NUDOCS 8108250432 | |
| Download: ML20030C140 (3) | |
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Constimers Power Company General Offices: 212 West Michigan Avenue, Jackson, MicYeon 49201 * (517) 788 4650 Janua y 30, 1981 Mr James G Keppler Office of Inspection and Enforce =ent Region III U S Uuclear Regulatory Co==ission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCEET 50-255 - LICE'iSE
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PALISADES PLANT - INF0PX Al RE0ARDING HEALTH PHYSICS APPRAISAL - SIGNIFICAUT APPRAISAL FINDINGS (REPORT 50-255/80-1L)
HRC letter dated Nove=ber 28, 1980, forwarded the results of the Health Physics Appraisal for the Palisades Plant conducted August L-15,1980. This letter identified seven (7) Significant Appraisal Findings ( Appendix A), and requested that Consumers Power Company formally respond to these findings within + ztr',
days of receipt.
In view of the extensive inspection effort and resulting volume of the Inspection Report, Consumers Power Company letter of Dece=ter 23, 1950, requested an extension until Msy 1,1981, for this response to permit a core
=eaningfu] review and evaluation of the Health Physics Program. NRC letter dated January 26, 1981, (received January 28, 1981) granted an extension to January 31, 1981. This letter provides the requested response.
The Significant Appraisal Findings can be classified into two general categories; those items for which specific action can be taken at the plant on a near-ter:
basis to improve specific actions or proce a es, and those ite=s which are program-
=atic in nature which should be addressel on a Corporate basis for all Censumers Power Company nuclear plants. Findings k and 7 fall primarily into the former category while Findings 1, 2, 3, 5, 6, and some aspects of L and 7 fall prl=arily within the latter.
With respect to Finding h, a progra= vas initiated at the beginning of 1981 at the Palisades Plant to formally review Health Physics procedures, among others, for consistency with standard plant and good health physics practices, and to verify completeness in light of Technical Specifications and other legal require-
=ents.
To date, several inconsistencies within and between Health Physics preced-ures have been found and elir.inated This progran is continuing and will include subsequent periedic reviews of all
'Ith Physics procedures on a regular basis.
l These aspects cf Finding 7 for which cion can be taken in the near term have been described in our letter of Dece ver 23, 1980, as our response to infraction nu=ber one.
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G K 03000255 PL,t
Mr James G Keppler 2
Palisades Plant January 30, 1981 On a prograr~ntic basis, we recognize that improvements can be made in the overall management and administration of activities related to Health Physics.
We are also aware of NRC efforts to strengthen Health Physics Programs at all nuclear plants. To address these issues, which generally include all.he Significant Appraisal Findings, Consumers Power Company is e= barking on a broad program to develop an upgraded, uniform Health Physics Program for all our nuclear plants. The essential elements of this program include in their scheduled sequence:
4 l.
Development of a Corporate Radiation Protection Plan. This plan includes listings of necessary procedures, better definition of responsibilities and authority of Corporate and plant Health Physics personnel end Corporate policies pertinent to Health Physics.
2.
Development of a Plant Radiation Protection Plan. This plan will supplement the Corporate Plan and will include descriptions of plant organization, facilities, equipment and other plant specific items as well as training requirements.
3 Development of (;rporate procedures to implement the radiation protection plans.
h.
Development and modification of plant procedures to implessnt the radiation protection plans.
5 Completion of all necessr.ry training.
It is expected that work will begin on the development of the above program in approximately h-6 weeks, and that the program can be fully i=plemented by late 1982.
Specifically we anticipate that the Corporate and Palisades Plant Rad.istion Protection Plans will be sub:Lantially complete by July 1,1981. An eight month period beyond July 1, vill be required for the development, modificatien and review of the implementing procedures with an additional eight month train-ing period following procedure completion.
Because of the magnitude of this progrsm, it is fully expected that a need for additional or modified facilities, equipment and personnel requirements vill be identified which cannot now be anticipated. In light of the above, we believe that the late 1982 date for full implementation of the revised Health 2nysics Program is reasonable.
The program outlined above provides a substantial ea. positive response to r
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the concerns raised in the Inspection Report, and c.rongly supports long-term
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Mr James G Keppler 3
Palisades Plant January 30, 1961 s
NRC goals in this area. We feel that this letter fully satisfies the request of your Nove=ber 28, 1980, letter.
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Robert A Vincent Staff Licensing Engineer CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcecent NRC Resident Inspector - Palisades Plant s
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