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)

Text

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consumers PmPH~r December 8, l978 cmup~my General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201

• Area Code 517 788-0550 Iv.Ir James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road qlen Ellyn, IL 60l37 l 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 I

i 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 I

• I 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 ~.individual 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 P~::t~ l JSlS ~

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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 ~rotection procedures.

Contrary to the above, Procedure H4P, 1.-1.2~21 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 radiat~.on surveillance and monitoring requirements for entry into high radiatio:p. area~:*- *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 .!I 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. Contrary to the above, the Waste Gas Monitor (RE-1113) calibration of December 16, 1977 did not cover the required count rate range.

B. Also contrary to the above, the Ga~eous Process Monitor identified as West Engineering Safeguards Gas Monitor (RE-1811) was not calibrated between April 16, 1976 .and June 2~, 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.

• RESPONSE A. . Corrective action taken included calibration of Monitor RE-1113 to the I 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 4~1' for RE-1811 and RE-1113 has been achieved. RE-0202 "\'Till be calibrated by January 2, 1979.

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])au-d P~JL'Vl(!Jii 1

David P Hoffman \ u O(J -

Assistant Nuclear Licensing Administrator

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CC: Director., Office of Nuclear R:~actor- Regu:Iation* -~:.

Director., Office of Inspection:: and Enforcement