ML20064F976
| ML20064F976 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/01/1982 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20064F960 | List: |
| References | |
| NUDOCS 8301110253 | |
| Download: ML20064F976 (3) | |
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Consumtf8 Power Company o.a..
on io4e w c.,a.o n. s, u, w 4eroi. se m na oseo Ilocomber 1.1982 Jamon U Koppler. Administrator Hagion 111 U!! Nucionr Hoguintory Comminnion 799 Hoonavalt. Rond Glen Ellyn.11. 60137 DGCKET 50-25$ - 1.ICEN!it I)pH PA1.l!!ADE!! Pl. ANT - HE!1p0N!iE TO 1H IN!1pECTION REI0RT ll2-22 IK Innpoetion Haport No 30-2$$/ft2-22 dated Octohor 211 19ti2 repor:od the renulta of n routina nnfety innpoetion conducted on floptember 20-24 19112.
Addronned in tha report woro two itemn of noncomplizinco to which runponnen are roepa i r ed. The itemn of noncomp!!nnen and romponnen thornto are given holow.
Connumorn Power Company in requenting by way of thin lottur, that the nucond item of noncomplinnce he witinirnwn. The datnlla of thin requent nro given af ter the renponnu to the accond item of noncompilance addronned in thin lotter.
ITEH licct ion 4.11.1 of the Technient tipocillent ionn. Appendix A ntatun in part "Hadiological environmentnl namplan uhnll be taken according to the following schedulo."
Thin nchedula npecif ten that milk in to ho collected monthly when avnlinble f rom four niten.
Contrary to the above. from Fohruary 19111 until Hny 19112 milk wnn collected from only three ulten.
HEtip0N!!E D!!iCilfill10N Prior to Fahruary 1981, milk enmplen woro gathered from four milk productton siten nn apacifled in Technten! fipoc!(icntionn pectton 4.I1.
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One of thone atten was the Kalame.a.co Dntry which nervnd an the monitoring program control attc.
In Fahrunty 19111. n Iiro damnged thu Kninmar.oo Dairy to the extent that milk unmplen could not bo obtained. Monthly DC1182-0020A-NI.02 DEC 3 082 i
H301110253 fl30104 POR ADOCK 05000255 O
PDH
JCKeppler, Adminictrct:r Palisades Plant Response to IEIR 82-22 e
December 1, 1982 attempts were made to obtain milk from the Kalamazoo Dairy, but it was not until August 1981 that the dairy informed Consumers Power that milk samples would no longer be provided. A determination was made, after reviewing Technical Specifications section 4.1.1, that we were not in violation of the Technical Specifications since the control milk sample was not available. A new sample point was not selected until May 1982 because of confusion regarding the responsibility for establishing the new site.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Four milk samples have been taken monthly since May 1982. Note, however, that since the missed samples were for the Palisades control site only,.we recognized, during the period from February 1981 to May 1982, that control camples from a site near the Big Rock Point Plant could have been substituted if necessary.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE The basic responsibilities for the environmental monitoring program are established in new Nuclear Operations Department Standard H05. Further-more, the Radiological Services Department procudures will be revised to translate these basic requirements into the working level details necessary to prevent recurrence.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED February 1, 1983.
ITEM Section 6.9.3.2 of the Technical Specifications, Appendix A, states in part:
"A report shall be submitted in the event that (a) the radiological monitoring programs are not substantially conducted as described in Section 4.11;... reports shall be submitted within 30 days."
Contrary to the above, no report was submitted when it became apparent that all samples specified in Section 4.11.1 of Appendix A Technical Specifications were not being collected.
DISCUSSION We have completed an investigation which confirmed that a review was conducted to determine reportability at the time of the missed samples.
Since the missed samples were the control samples, and adequate backup OC1182-0020A-NLO2
JGXepplcr 'Admihictrntcr Palisades Plant
. Response to IEIR 82-22 L
a-December 1, 1982 was available from the Big Rock Point Plant control site, we concluded that the missing samples did not in fact constitute a substantial degradation in the radiological environmental monitoring program.
Accordingly, no special report was submitted to the NRC.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE Responsibilities for the environmental monitoring program are established in the new Nuclear Operations Dept Standard H05. Furthermore, the Radiological Services Dept procedures are being revised to translate these requirements to working level detail necessary to prevent reocurrence.
Specifically, all discrepancies and evaluations of the program are to be documented to file and multiple discrepancies are to be entered into the corrective action system.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED February 1, 1983.
REQUEST FOR ITEM OF NONCOMPLIANCE TO BE WITHDRAWN We believe that this cited noncompliance is directly related to the first item of noncompliance and should have been included with the first item as a single noncompliance. We view the segregation of this event into two noncompliances as not appropriate given the publication of other items of noncompliance which were not as closely related as this event, but were combined into a single noncompliance.
Based upon the results of the investigation described above, Consumers Power Company contends that the radiological environmental monitoring program was substantially conducted and no report was required as per Palisades Technical Specification 6.9.3.2.
Therefore, we request that this item of noncompliance be withdrawn.
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$Uf David J andeWalle Nutlear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director Of fice of Inspection and Enforcement NRC Resident Inspector - Palisades OC1182-0020A-NLO2
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