IR 05000155/1997014

Discusses Insp Rept 50-155/97-14 from July to Sept of 1996 & Forwards Notice of Violation.Violations Concerning Radiation Surveys Not Completed as Indicated in Station Records on Three Separate Occasions

ML20199J437
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/19/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20199J443	List: IR 05000155/1997014 ML20199J457
References
50-155-97-14, EA-97-239, NUDOCS 9711280144
Download: ML20199J437 (3)

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November it 1997 EA 97-239 Mr. K. Plant General Manager Big Rock Point nuclear Plant Consumers Energy Company 10269 US 31 North Charlevoix, MI 49720 SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report No. 50-155/97014)

Dear Mr. Powers:

This refert, to our investigation of the falsification of various radiation protection survey records at your plant by a member of your Radiation Protection Department from July to September 1996.

At this time, we have completed our review of these iricidents. Based on the information that you provided in various documents and correspondence (those listed in our June 12,1997 letter to you, plus requested source documents), as well as the absenc3 of any contradictory information from the iridividua! concerned, the NRC has determined that two violations of NRC requirements occurred. Specifically, radia%n surveya required by station procedures were not completed as indicated in station records on three separate occasions. On July 21,1996, a required daily cir sample on the 585' level of the Reactor Containment Building was not completed; on July 20 and 21,1996, a required daily radiation survey for the exterior cable penetrr. tion room was not conducted; and on September 16 199f, both a required monthly survey and a required air sample for the Radwaste Building were not completed. In all three instances, the individual responsible for the surysys faWfied the applicable survey records to ,

dicate that these tasks had been performed. These failures to comply with a Technical

. pecification-required procedure goveming radiation surveys constituted a violation of Technical Specification 6.11. In addition, the fact that plant records of these surveys contained false information and were not accurate in all material respects was a violation of 10 CFR 50.9.

The NRC recognizes that the actual safety significance of the incident was low because the areas to be surveyed were not high radiation areas or airbome radioactivity areas and subsequent surveys did not indicate any significant changes in radiological conditions.

However, the potential safety significance of failing to survey plant areas and then denoting false results on survey document:: is relatively high for: 1) plant workers entering areas where radiological conditions may have changed or 2) from an operations standpoint, where changing radiological conditions could indicate a problem with plant systems or operation. TMse actions are of particular concern because of the reliance of plant personnel, as well as the public and the NRC, on tho accuracy of plant records, especially radiation survey records. In addition, deliberate violations are of special concem because the NRC's regulatory programs cre based on licensees and their employees acting with integrity. The falsification of records is a svillful act

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C November 19, 1997 which will not be tolerated. It is essential that the NRC be able to maintain the highest trust in individuals working in a nuclear power plant and that licensees appropriately manage their programs to ensure that personnel fully understand the importance of complying with regulatory requirements. As the licensed entity, Consumers Energy is ultimately responsible for the acts of its employees.

The violations are cited in the enclosed Notice of Violation (Notice). These violations have been categorized in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG 1600 as Severity Level IV violations. The NRC consider 9d citing these as Non-Cited Violations because they were identified, investigated and promptly corrected by your staff. However, the NRC chose to issuo the violations as Severity Level IV because of their repetit:veness and potential safety significance. We note that the same individual was involved in records falsification at Big Rock Point in October 1991 (EA 92 235), and individual enforcement action against him is being considered for the current violations.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the spec'fic actions taken ud any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room (PDR),

Sincerely, Original Signed by John A. Grobe John A. Grobe, Director Division of Reactor Safety Docket No. 50-155 License No. DPR-6 Enclosure: Notice of Violation cc w/ encl: R. A. Fenech, Senior Vice President, Nuclear, Fossil, and Hydro Operations James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Department of Attorney General (MI)

See Attached Distribution DOCUMENT NAME: G:DRS' BRP11197.DRS To receive e copy of this document. Indicato in the box: 'C' = Copy w/o attlenci *E' = Copy w/att/enct "N" = No copy OFFICE SIJ! g,g E Rlli lC RflQ l11 Rlll le Rlli ,, R NAME WestilfF Shears % Bf/fdess Clayton & GrobeU lDATE 11//y/97 11/4/97 N 10W97 11/d/97' 11/ YY97 0FFICIAL RECORD COPY

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l . November 19,1997.

Distribution:

Docket File w/enct SRis, BRP, Palis w/enci CAA1 w/enci PUBLIC IE-01 w/enci LPM, NRR w/enct J. Lieberman, OE w/enci OC/LFDCB w/enct A. B. Beach, Rlll w/enci J. Goldberg, OGC w/enci DRP w/enci J. L. Caldwell, Rif t w/enci R. Zimmerman, NRR w/anci DRS w/enci Rlli Enf. Coordinotor w/enci Rill PRR w/ encl TSS w/enci

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