ML20063N507
| ML20063N507 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/10/1982 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20063N489 | List: |
| References | |
| NUDOCS 8209220126 | |
| Download: ML20063N507 (3) | |
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Consumers Power Company Generei offices: 1945 West Parnali Road, Jackson, MI 49201 e (517) 788-0550 7
September 10, 1982 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO IE INSPECTION REPORT 82-18 The NRC reported the results of a special safety inspecticn conducted on July 28 - 29, 1982 in IE Inspection Report No 50-255/82-18. Addressed in the report was one item of noncompliance to which a response is required.
The item of noncompliance and response thereto is as follows:
ITEM:
Technical Specification 6.8.1.a requires implemenation of applicable j
procedures as recoriaended in Regulatory Guide 1.33, Appendix "A" (November 1972), which includes administrative procedures. Administra-time Procedure 3.6, "ALARA Committee", states the ALARA Committee vill meet bimonthly and that, among other duties, they will perform ALARA reviews of jobs which have established doses of greater than 5 person-rems.
Contrary to the above, there have been no ALARA Committee meetings for at least one year, and ALARA reviews of contractor jobs exceeding 5 person-rems have not been routinely conducted.
RESPONSE
Corrective Action Taken and Results Achieved t
The last formal meeting of the plant ALARA Committee took place on April 21, 1981. The next regular meeting would have been held in June of the same year, but was not scheduled because of the high level of activity devoted at that time to completing preparations for the 1981 Refueling Outage. Furthermore, because of difficulties encountered in defining the scope of the major modifications planned i
for this outage, all contractor work was not reviewed for ALARA l
considerations by a member of the Health Physics Staff.
(
I 8209220126 820915 SEP 13 082(
PDR ADOCK 05000255 G
E JGKeppler, Administrator 2
Palisades Plant RESPONSE TO IEIR 82-18 September 10, 1982 RESPONSE: (Continued)
Corrective Action Taken and Results Achieved (Continued)
Two new positions, Corporate and Plant ALARA Coordinator were created in 1981, and the Palisades Plant position was filled August 1981. While no ALARA Committee meetings were held during the proceeding year, which included the Refueling Outage and Steam Generator Outage, several modifications and projects performed during this time did receive documented ALARA reviews. In addition, the Plant ALARA Coordinator continued his review on a task-by-task basis and began preparation of a new ALARA Program Administrative Procedure (7 02) to implement the program guidance provided by the Corporate Radiation Safety Plan.
Administrative Procedure 7.02 has since been completed and an ALARA Committee meeting was held on August 30, 1982. The Committee will meet quarterly instead of bimonthly, is chaired by the Plant Manager, and is made up of the Operations and Maintenance Superintendent,
Technical Superintendent, Chemistry / Health Physics Superintendent, Plant Health Physicist and a corporate Health Physics representative.
This ALARA committee has two principal objectives:
1.
Develop measures of effectiveness by which the ALARA Program could be evaluated.
2.
Provide an independent high level review of the Radiation Safety Program, ensuring a consistent demonstration of the plant management's commitment to exposure reduction.
The ALARA Committee will meet these objectives by performing the following functions specified in Procedure 7.02.
1.
Finalize the annual ALARA goals for the Plant Manager's approval.
2.
Review progress achieved in the process of meeting stated goals.
3.
Review the cummulative annual exposure analysis.
4.
Review past job analyses for specific exposure commitments of 25 person-rem or more.
5 Review the analysis of exposure history for individuals whose exposure exceeds 3 rem.
6.
Review the investigation of any exposures, internal or external, in excess of prescribed administrative limits.
The high level of plant management involvement in the ALARA Committee and the implementation of a fermal ALARA Program via the ALARA Program Administrative Procedure 7.02 ensures that ALARA Committee meetings will be held at least quarterly.
JGKeppler, Administrator 3
Palisadec Plant FISPONSE TO IEIR 82-18 September 10, 1982 Corrective Action To Be Taken To Avoid Further Noncompliance The implementation of the ALARA Program via Procedure 7.02, and plant management's involvement in this program, will prevent further noncompliance.
Date When Full Compliance Will Be Achieved Full compliance was achieved with implementation of the AIARA Program on August 13, 1982, and the August 30, 1982 meeting of the AIARA Committee.
k David VandeWalle Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades