ML18064A848

Responds to Violation Noted in Insp Rept 50-255/95-07 on 950413-0527.Corrective Actions:Air Sampling Portion of REMP Now Being Completed by Plant Radiological Svcs Dept & HP Procedure 10.10 Will Be Revised

ML18064A848
Person / Time
Site:	Palisades
Issue date:	07/27/1995
From:	Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9508010057
Download: ML18064A848 (4)

See also: IR 05000255/1995007

Text

• * @consumers

• Power PllWEIUN&

MICHl&Alll"S

l'IUl&llESS . Palisades

Nuclear Plant: 27780 Blue Star Memorial Highway, _Covert, Ml 49043 July.27, 1995 U S Nuclear Regulatory

Commission

Document Control Desk * Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT _ KurtM. Haas Plant Safety and Licensing

Director REPLY TO NOTICE OF VIOLATION

-SAMPLING DEFICIENCIES

IN RADIOLOGICAL

ENVIRONMENTAL

MONITORING

PROGRAM NRC Inspection

Report No. 50-255/95007(DRP)

contained

a Notice of Violation

for a Severity Level IV Violation

involving

the failure to correct sampling deficiencies

in the Radiological

Environmental

Monitoring

Program. Attachment

1 contains our response to the vi6lation.

SUMMARY OF COMMITMENTS

This letter contains four new commitments.

I. The deficient

air sample techniques

used by the contractor

will be evaluated

to determine

the validity of past air sample .results.

2. Health Physics Procedure

10.10; "Pali sades Radiological

Environmental

Program Sample Collection

and

will be revised to

clear expectations

for air sampling.

3. The Radiological

Services Department

sample collectors

will.be trained on the revised sampling

• -4. As part of the Radiological

Services Department's

self assessment

program, annual self assessments

will be performed

on the environmental

monitoring

program. * I Kurt M. Haas Plant Safety and Licensing

Director CC Administrator, Region III, USNRC Project Manager, NRR, USNRC NRC Resident Inspector

-Palisades

Attachment

9508010057

950727 PDR ADOCK 05000255 Q PDR A CMS' ENERGY COMPANY fff/t 'l !

ATIACHMENT

1 CONSUMERS

POWER COMPANY PALISADES

PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION

SAMPLING DEFICIENCIES

IN RADIOLOGICAL

ENVIRONMENTAL

MONITORING

PROGRAM 2 Pages

'NRC VIOLATION

REPLY TO NOTICE OF VIOLATION

SAMPLING DEFICIENCIES

IN RADIOLOGICAL

ENVIRONMENTAL

MONITORING

PROGRAM During an'NRC inspection

conducted

from Apri1 13 through Hay 27, 1995, a. violation

of NRC requirements

was identified.

• In accordance

with the "Genera] Statement

of Po1icy and Procedure

for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C, the vio1ati0n

is 1isted be1ow: * Technical

Specification

6.8.4.b and 6.5.2.4.2.j

respectively

require a program to monitor the radiation

and radionuc1ides

of the Pa1isades

Nuclear P1ant and audits of the radio1ogica1

environmental

monitoring

program. 10 CFR 50 Appendix 8 Criterion

XVI requires that identified

deficiencies

be promptly identified

and corrected.

Contrary to the above, sampling deficiencies

in the radio1ogica1

environmental

monitoring

program remained uncorrected

after being identified

by the Nuclear Performance

Assessment

Department

in October 1991 and October 1992. This is a Severity Leve1 IV violation

.. (Supplement

IV) CONSUMERS

POWER COMPANY RESPONSE Background.

Plant review of the event confirmed

that past Nuclear Performance

Assessment

Department (NPAD) audits as far back. as 1990 had identified

similar problems with inadequate

sampling techniques.

Following

the 1990 NPAD audit, NPAD reconvnended

replacing

the local sampling contractor

by performing

the sampling in-house.

Discussions

with four Radiological

Environmental

Monitoring

Program (REHP) supervisors

indicated

that they all had discussed

proper sampling techniques

with the contractor.

Three of the past REMP supervisors

stated that they had recommended

the replacement

of the local sampling contractor.

Recommendations

to terminate

the local sampling contractor

were not approved by plant management

due to factors other than job performance.

These other factors included concerns with convnunity

relations

coupled with a de$ire to maintain local residents

employed at the plant. The local sampling contractor

-was a local conununity

leader and had held this and similar jobs for many years with the plant *. The management

decisions

to retain the same contractor

to obtain the samples was based on the thought that, once properly trained, the local sampling contractor

could meet the sampling expectations:

However, NPAD audits in 1991 and 1992 continued

to show various problems with the way that samples were taken. As a follow-up

to these audits, the contractor

received training aimed at improving

performance

for the issues identified

during the audits.

NPA!r audits from late 1993 found no deficiencies

with the sampling program, which may have given plant management

the feedback that the contractor . sampling training goals had been met. However, investigations

completed

as a result of the identification

of the recent performance

issues determined

that a relative of the normal local sampling contractor, with the same initialS as the normal contractor, was actually observed taking the samples during the 2 1993 audit. Based on the most recent occurrences, it is evident that observed.

improvement

in performance

was short-lived

and. was not attributable

to the local sample collector

normally performing

the work. Reason for the Violation

The reason for the violation

was a plant management

decision to correct the sampling performance

deficiencies

by retraining

and surveillance

of the local sampling contractor, rather than by replacing

the contractor.

A contributing

factor was also a failure to identify that the 1993 audit findings did not represent

a program improvement

base.d on who was actually performing

the sampling.

• Corrective

Steps Taken and Results Achieved The air sampling portion of the REMP program is now being completed

by the plant Radiological

Services Department.

REMP program supervisors, as part of their supervision

responsibilities, will be monitoring

the field sampling activities.

The balance of the

sampling program was looked at and no other problems were identified

with the sampling service. Based on discussions

• with individuals

involved with administering

contractors

and contracts

for the plant, .this has been determined

to be an isolated event. The deficient

air sampling techniques

used by the local sampling contractor

will be evaluated

to determine

the validity of past air sample results. As part of the Radiological

Services Department's

self-assessment

program, annual self-assessments

will be performed

on the environmental

monitoring

program. Corrective

Steps Taken to Avoid further Violations

Physics Procedure

10.10, uPalisades

Radiological

Environmental

Program Sample Collection

and Shipment," will be revised to clarify expectations

for air sampling.

The Radiologic*l

Services

sample collectori

will be trained on the revised sampling procedures.

Date When Full Compliance

Will Be Achieved full compliance

has been achieved with reassignment

of the air sampling program to the Radiological

Services Department.