ML20151C210
| ML20151C210 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Palisades |
| Issue date: | 01/28/1981 |
| From: | Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20151C214 | List: |
| References | |
| FOIA-88-353 EGM-81-05, EGM-81-5, NUDOCS 8103110626 | |
| Download: ML20151C210 (2) | |
Text
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'E UNITED STATES NUCLEAR REGULATORY C2MMISSION
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EGM-81-05 tiEN0RANDUM FOR:
James G. Xeppler, Director Region III 7
FROM:
Dudley Thompson, Director Enforcement and Investigations, IE
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SUBJECT:
CONTESTED fiONCOMPLIANCE - PALISADES HEALTH PHYSICS APPRAISAL
Reference:
Keppler memo dtd January 19, 1981 The proposed violation regarding the timeliness of completing a survey (evaluation) for purposes of calculating the total amount of radioactivity released from the Palisades stack appears to be inappropriate in this particular case; i.e., the inability of personnel to complete the evaluation in less than 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />; for the following reasons:
1.
The release was terminated within a reasonably short period of time by the shift supervisor, thereby alleviating the problem; all that remained was the evaluation of the magnitude of the release, ex post facto.
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Had imC personnel not been present at the site, any subsequent reports, had they been required, would most likely not have addressed the time needed to perform the evaluation,,nly the results and time of occurrence.
3.
The licensee apparently concluded correctly from previous similar increases in releases of the same magnitude that off-site emergency procedures would l
not need to be implemented.
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We agree that the relatively simple conversion factors needed for such evaluations should be part of their energency procedures (if they are not already) and further, that plant personnel should kr.ow those procedures 4
as well as the kinds of equipment being used (linear and logarithmic recorders). We also note that the licensee has apparently taken more than just acceptable corrective measures.
As stated above, we believe that the ticeliness of the evaluation % not a valid reason for citing the licensee in this case.
That is not to say that there is no+ noncompliance involved, froTthe standpoint of insufficient training and/or lack of implementation of appropriate emergency procedures to evaluate releases.
Contact:
J. Metzger (28188)
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James G. Keppler,
I There are cases where "surveys" as defined in Part 20 must be immediate for making evaluations to preclude an emergency situation; e.g., performing a physical survey on radiographic equipment upon source retraction, knowing (evaluating) when to terminate a stack release, etc.
In summary, we believe that the noncompliance should be couched in terms of availability of emergency procedures and training in the use of such procedures i
if they exist.
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- Dud,ey,Thbmpson D'irector Enforceme.nt and Investigations Office of Inspection and Enforcement ec:
T. Brockett J. Riesland G. Barber J. fietzger i
1.. B. Higginbotham G. Snyder, RI i
C. Upright, RII C. Norelius, RIII W. Vetter, RIV
/.. Johnson, RV j
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