ML20079J735
| ML20079J735 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/02/1982 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8212280330 | |
| Download: ML20079J735 (3) | |
Text
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be Consumets Power Company General Offices: 1946 West Parnell Road, Jackson, MI 49201 e (517) 788-0550 December 2, 1982 t'
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James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn. IL 60137 DOCKET 50-255 - LICENSE DPR PALISADE 3 PLANT - RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM CORRECTIVE ACTION - REFERENCE IE INSPECTION REPORT 82-22 IE Inspection Report 82-22, dated October 28, 1982, provided the results of an unannounced inspection of, among other areas, the Radiological Environmental Monitoring Program (REMP) at the Palisades Plant. This Inspection Report noted the NRC's concerrt with the weak state of the REMP, as identified by their inspection, and requested that Consumers Power Company submit plans for corrective action, including a timetable for accomplishment, to the NRC -
Region III office. The fellowing is our response to this request.
A thorough review has been performed of the existing plant and General Office procedures relating to radiological environmental monitoring activities.
Included in this review were the Consumers Power Company Quality' Assurance Department Audit Reports for the years 1981 and 1982, as well as the 1981 NRC SALP Report for the Palisades Plant and the details of Inspection Report 82-22.
Supervisors who have been active in the implementat. ion of the REMP during the past several years were interviewed to determine the distribution of responsibilities with program.
This investigation identified two weaknesses in the REMP. The principal weakness has been the lack of established management controls sufficient enough to ensure consistency in meeting the Palisades Technical Specifications requirements. While program responsibilities were shared by various groups within Consumers Power Company, as well as by a contractor, existing procedures did not define this distribution accurately.
The second weakness resulted from the inadequate quality of some of the working level procedures at the Palisades Plant. This weakness has been l
identified by the internal audits of chemistry and environmental activities conducted in 1981, and to date, some progress has been made in these areas.
8212280330 821202 PDR ADOCK 05000255 0
PDR OC1282-0003A-NLO2 g?.
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JGK;pplcr, Admini;trctor' 2
Palisades Plant Rad Env Monitor Program Correct Action - IEIR 82-22 December 2, 1982
- The following comprehensive corrective action plan including expected or achieved completion dates, has been instituted to eliminate the weaknesses identified in the REMP.
Publish the Nuclear Operations Department Standard, Complete -
H-05, " Radiological Environmental Monitoring. This 4/1/82 Standard distributes program responsibilities between the General Office Radiological Services Department and the Plant Chemistry / Health Physics Department.
Publish the Nuclear Operations Department Chemistry Complete -
Program Manual. This manual establishes improved 10/18/82 standards for sampling and analytical procedures, including performance quality control, data manage-ment, and corrective action.
(Note: This action I
item also addresses the expected issuance of a cor-porate level procedures manual mentioned in IE Inspec-tion Report 82-22, paragraph 4, "QA/AC of Analytical Measurements".)
Publish a total of 6 Administrative and Environ-2/1/83 mental Procedures for the Radiological Services Depart-ment. These procedures define working level details and responsibilities for the evaluation of data, monitoring contractor performance, preparing reports, and resolving problems.
1 Publish a new Palisades Plant Administrative Procedure 12/21/82 i
on the Environmental Program which assigns responsibili-ties at each level within the Plant organization and defines interfaces with the Radiological Services Depart-ment.
i Publish a new Chemistry Operating Procedure for the 1/31/83 REMP which tabulates required sample and monitoring points, frequency of sampling, related working level procedures, and action responses to off-normal situations in a matrix forn.
P OC1282-0003A-NLO2
.n JGKeppler, Administrator 3
Palisades Plant Rad Env Monitor Program Correct Action - IEIR 82-22 l
December 2, 1982 I
Upgrade twelve Health Physics working level procedures 2/28/83 to conform with new standards.
Upgrade approximately eighteen Chemistry working level 3/31/83 procedures to conform with new standards.
Brian D Johnson Staff Licensing Engineer CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades OC1282-0003A-NLO2
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