ML18043A372

Responds to NRC 780421 Ltr Re Violations Noted in Insp Rept 50-255/78-21.Corrective Actions:Overexposed Employee Removed from Work in Radiation Areas, & Limited Radiation Access Authorization Developed

ML18043A372
Person / Time
Site:	Palisades
Issue date:	12/08/1978
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7901050351
Download: ML18043A372 (3)

See also: IR 05000255/1978021

Text

• .i l '! I i I ** I i L . ":--* * consumers

General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * Area Code 517 788-0550 . . . December 8, l978 Iv.Ir James G Keppler Office of Inspection

and Enforcement

Region III US Nuclear Regulatory

Commission

799 Roosevelt

Road qlen Ellyn, IL 60l37 DOCKET 50-25 5 -LICENSE DPR-2CL-PALISADES

PLANT IE INSPECTION

REPORT 78-2l ConsUlllers

Power Company appreciates

the extension

granted by the NRC (phone conversation, B Jorgensen-GS

Cashell, December 7, l978@ 4:15 PM EST) regarding

our response to IE Inspection

• Report /7.8-2l. .... Our response to the apparent items of noncompliance

delineated

in IE Inspi:=ction

Report 78..,,..2l

is as follows: ITEM 1-* INFRACTION

10 CFR Part . 20 .101 (b) iimits -whole body -dose to three. rems_ per. calendar_*-<+/-uarter

• from ... radioactive

material and other sources of radiation

.. iri .. your possession

when the indi.vidual'

s accumulated.,qccupational

.. dose. to the whole body has been determined-on

Form-NRG-4-and-whenthe

accumulatedoccupational

dose will ... not exceed 5 (N-18) rems,. where "N" is. the

1 s age. Contrary to the above, you reported by .letter dated April 2l, 1978 that a worker received a 3.26 rem dose to the whole body (head) during the first calendar quarter of l978, based on your *official

film badge data. RESPONSE A .. The immediate

corrective

action taken upon discovery

of the overexposure

was to* remove the individual

from work in radiation

areas. This employee was not permitted

any further occupational

radiation

exposure for the remainder

of the .calendar

quarter. A report of personnel

overexposure

was made to the NRC (letter from D P Hoffman to J G Keppler dated April 21, 1978. B. To avoid future instances

of noncompliance, radiation

monitoring

and surveillance

activities

which were previously

assigned to Radiation

Work Permit (RWP)'exempt

individuals

have been limited and will be suspended

after January 2, l979. Additionally, training and requalification

sessions have been conducted

on the topics of radiation

monitoring

and entry into high radiation

areas, and use or the Radiation

Work

l JSlS 7 9 0 1 0

5 @ 35"1

C. Full compliance

with 10 CFR Part 20.lOl(b)

has been maintained .since* this instance of suspected*overexposure

on February 24, 1978. ITEM 2 -INFRACTION

Technical

Specification

6.11.1 requires adherence

to radiation

procedures.

Contrary to the above, Procedure

H4P,

governing

Radiation

Work Permits (RWP). was not followed, in that three maintenance

men who were not specifically

authorized

for RWP exemption

worked within a restricted

area on February 23, 1978 without a Radiation

Work Permit or direct supervislon

by the Radiation

Protection

Group. One of the workers was overex:Posed

to eXternal radiation, as noted in Item-1 above. RESPONSE A. As stated in Item 1 abo.ve, the use of full RWP-exempt

personnel

as qualified

radiation

monitors has been limited since the February 24 incident.

Additional

training has been provided to personnel

involved.

Requalification

programs have addressed

surveillance

and monitoring

requirements

for entry into high radiatio:p.

• No addi tiOnal overexposures

have occurred.

--*** _1 .... B. To avoid future instances

of noncompliance, the RWP exemption

pr_ogra.m

has been reviewed.

As a result of this review, it was decided to eliminate

the RWP exemption (to be completed

by January 2, 1979). A new program kllown as the Limited Radiation

Access Authorization (LRAA) program has been developed

which will require individuals

entering a high radiation

area to have a Radiation

Work Permit or to be accompanied

by qualified

monitoring

personnel.

C. Training for this new LRAA program is presently

in progress and will be completed

by January 2, 1979, at which time the LRAA program will go into effect. Once the program has been implemented, this item of noncompliance

will be closed out. ITEM 3 -INFRACTION

Technical

Specification

4.1 requires calibration

of process monitors at least once per 18 months. A. B. Contrary to the above, the Waste Gas Monitor (RE-1113)

calibration

of December 16, 1977 did not cover the required count rate range. Also contrary to the above, the

Process Monitor identified

as West Engineering

Safeguards

Gas Monitor (RE-1811)

was not calibrated

between April 16, 1976 .and June 1978, a period of 26 months. Also contrary to the above, the Liquid Process Monitor identified

as the Volume Control Tank Monitor (RIA-202)

was last calibrated

April 17, 1976, twenty-nine

months ago. .! I

• RESPONSE A. . Corrective

action taken included calibration

of Monitor RE-1113 to the 105 count/minute

range, repair and calibration

of RE-1811 and modification

of RE-0202. The calibration

• of RE-0202 is in progress.

B. Corrective

action taken to* avoid: __ future noncompliance

will include a review .of the calibration

frequency

• t'ickler

system.. In adqition, the Plant Health Physicist

will review the calibrat{on

records following

a calibration

to ensure that an adequate calibration

has been performed.

C. Full compliance

with Technical

Specification

for RE-1811 and RE-1113 has been achieved.

RE-0202 "\'Till be calibrated

by January 2, 1979. ])au-d P

David P Hoffman 1 \ u O(J -Assistant

Nuclear Licensing

Administrator . ** .i ,._ CC: ** Director., Office of Nuclear

Regu:Iation*

Director., Office of Inspection::

and Enforcement

' . I i*. I.