ML20087P803
| ML20087P803 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/12/1984 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20087P800 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8404090383 | |
| Download: ML20087P803 (4) | |
Text
4 A e E..
Consumers Power Company General offices: 1945 West Parnait Road, Jackson, MI 49201 * (S17) 788-0550 March 12, 1984 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONiE TO IE INSPECTION REPORT 84-01 IE Inspection Report No 50-255/84-01 dated February 9, 1984 reported the results of a special safety evaluation inspection conducted during January 1984. Addressed in the report were two (2) items of non-compliance to which responses are required.
The items of non-compliance and responses thereto are given below:
Item No 1:
Technical Specification 6.2.2 states that the Plant organization shall be as shown on Figure 6.2-2, which shows the Health Physicist (Radiation Protection. Manager) reporting directly to the Generating Plant Superinten-dent.
Contrary to the above, the Chemistry and Health Physics Superintendent (Radiation Protection Manager) has been reporting to the Operations and Maintenance Superintendent since at least Deceder 1982.
Response To Item No 1:
During the past five years, the size of the Palisades Plant staff has
-increased significantly.
In order to manage the increased staff effectively, several new management positions were created, including those of the Operations and Maintenance-(0&M) Superintendent and the Chemistry /
Health Physics Superintendent. Organizational reporting relationships were subsequently revised such that the Chemistry / Health Physics Superintendent (Radiation Protection Manager) reports to the O&M Superintendent, who in turn reports to the Plant Manager.
8404090383 840406 PDRADOCK05000gg
~
i G
-OC0384-0002CC-NLO2
$ 4
=
n, 1'
LJGK2pplar. Adzinistrator 2
ct',
Pnlisades Plant.
1EESPONSE TO-IEIR 84-01 March 12,.1984 In reviewing ~the' requirement for the Health Physicist (Radiation Protection
- Mana'ger) to report directly to'the Plant Manager, the Plant Staff interpreted the' requirement to mean the individual responsible for radiation. safety. (Radiation. Protection Manager) should have direct access to;the. Plant Manager in matters of radiation safety.
- Consequently, a proposed Technical Specifications change was submitted in December 1982 which reflects this interpretation.
Corrective Action Taken and Results Achieved A proposed Technical Specifications change request was submitted to the NRC on December 20,.1982 to reflect the existing Plant organization. Recent conversations with the Office of Nuclear Reactor Regulation indicate.the
. proposed organization is acceptable and approval of the change request is imminent.
Corrective Action to be Taken to Avoid Further' Noncompliance None
- Date When Full Compliance Will be Achieved Full compliance will be achieved upon approval of the proposed Technical
' Specifications change.
Item No'2:-
c 10'CFR 50.54(h) states that'the licensee shall be subject to the provisions of the. rules, regulations, an'd. orders of the Commission. On March 14, 1983, the Commission issued an Order confirming the licensee's commitments
~
on post-TMI related~1ssues. The Order states, in~part, that the licensee sh'all; implement and maintain the specific 11tems described as. complete in -
the--attachments to the Order.E Attachment I to the Order lists the lic'ensee's completion schedule date for NUREG-0737 Item II.F.1.1, " Noble-Gas! Effluent Monitor" as July 1, 1983. NUREG-0737 Item II.F.1.1, TClarificationLNo. 1, requires-~ continuous monitoring and a display which reads'out in'aicrocuries per cubic centimeter or as equivalent Xe-133 concentrations.
- Contrary 'to' the' above, the licensee's noble gas ef fluent monitor reads out
{
~
.in counts per minute on'the lowirange and mR/hr on the high. range. Also, I
~
(the continuous monitoring must be interrupted in order to change the particulate. filter and iodine cartridge.
OCO384-0002CC-NLO2 m
L
'JGKcppler, Ad:linistrator 3
s.
Palisades Plant RESPONSE TO IEIR 84-01 March 12, 1984
Response
The Palisades Plant stack gas monitors employ a beta scintillation detector to measure noble gas encountered during normal operation. An ionization chamber is used to measure higher noble gas concentrations which would be encountered during accident conditions.
The output of the beta scintilla-tion detector is displayed in units of " counts per minute" (cpm), while the ionization chamber output is displayed in units of mR/hr. These display units are considered more accurate than pCi/cc or Xe-133 equivalent concentration for the Palisades Plant monitors, because the Palisades Plant monitors are not designed to compensate for the particular mixture of noble gas radionuclides being monitored. The particular mixture will change with core burnup, the rate of release of noble gases from the core, and time after shutdown.
To properly account for the changing gas mixture, a set of curves has been developed and procedurally implemented which convert the displayed monitor response to a release rate in units of pCi/su. Therefore, it is our belief that the existing Noble gas effluent monitor display, when used in conjunction with the associated curves, fully satisfies the intent of the display' criterion specified in NUREG-0737, Table II.F.1.1.
However, the NRC in a letter from DMCrutchfield dated March 7, 1984, has concluded that
- the existing display is unacceptable and must be modified. We are evaluating possible procedure and/or equipment changes and will respond within the 30 days specified by the letter.
Information provided to the Inspector at the time of the inspection regarding continuous monitoring was inaccurate, leading to the conclusion that the required continuous monitoring capability must be interrupted to change the accident cartridge.
Subsequent review of the system design indicates that the normal particulate filter and iodine cartridge, as well as the accident cartridge, may all be changed without interrupting the continuous monitoring capability of the high range noble gas monitor, as specified in Clarification 1 of NUREG-0737, Item II.F.1.1.
-Corrective Action Taken and Results Achieved
- 1) A response to NRC letter dated March 7, 1984 regarding the radioactive gas effluent monitor display will be provided within 30 days.
2)' Several misleading steps concerning system purging in the Emergency Implementing Procedure for accident conditions sampling have been corrected.
~0C0384-0002CC-NLO2 L
~.
e-
.JGKipplsr, Adninistrator 4
Palisades Plant RESPONSE TO IEIR 84-01
. March 12, 1984 Corrective Action to be Taken to Avoid Further Noncompliance
' Personnel responsible for project implementation will be advised of this occurrence and the importance of documenting deviations from established design criteria as they are identified.
Date When Full' Compliance 'Will be Achieved
~
A schedule will be provided in response to the March 7,1984 letter from DMCrutchfield..
h,W OMdlU)
David J.
andeWalle Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement
'NRC Resident Inspector - Palisades e
f OC0384-0002CC-NLO2