IR 05000155/1997015
| ML20217B564 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/20/1998 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| 50-155-97-15, NUDOCS 9803260101 | |
| Download: ML20217B564 (1) | |
Text
{{#Wiki_filter:==SUBJECT:== NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-155/97015(DNMS))
Dear Mr. Powers:
This will acknowledge receipt of your letter dated March 11,1998, in response to our letter dated February 14,1998, transmitting a Notice of Violation associated with inspection Report 50-155/97015(DNMS). We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
Sincerely, /s/ Ross B. Landsman Bruce L. Jorgensen, Chief Decommissioning Branch Docket No. 50-155 License No. DPR-6 cc: R. A. Fenech, Senior Vice President, Nuclear, Fossil, and Hydro Operations Richard Whale, Michigan Public Service Commission Michigan Department of Public Health ! . Department of Attomey General (MI) bec w/Itr did 3/11/98: PUBLIC IE01 9803260101 900320 PDR ADOCK 05000155 G PDR DOCUMENT NAME: G:\\SEC\\BRP97015.LO1 To receive e copy of th6e document, indicate in the boxfC" a Copy without enclosure Tm Copy with enclosureYa No copy l OFFICE Rill - _.
jC Rlli - . _ lC l lNAME Landsman /dp KSC f*Joroensen )Wtf lDATE 03/14 98 03/20/98 OFRCIAL RECORD COPY y
, - _ ' t ? M l M!M A CMS Energy Cornpany Big Rxk Point Nxicar Plant 10269 LG-31 North Ste General Manager Charleox, MI 49720 {d March 11, 1998 Nuclear Regulatory Commission j - Document Control Desk i Washington, DC 20555-0001 DOCKET 50-155 - LICENSE DPR-6 - BIG ROCK POINT PLANT - REPLY TO NOTICE OF VIOLATION - NRC INSPECTION REPORT 97015 During an NRC inspection of decommissioning activities at Big Rock Point, completed February 2,1998, a violation of NRC requirements i was identified and forwarded by letter dated February 14, 1998.
l The violation involved the failure of a worker in a high radiation ) ' area tu check his personal dosimetry every 15 minutes as required by plant procedure.
Consumers Energy Company concurs with the NRC ' in that the violation is of concern, because the basic health physics prcctice of self-monitoring was not performed by the worker while in a high radiation area, and because such self-monitoring, had it been performed as required, would have disclosed that the
electronic dosimeter was not in the operating mode.
Consumers Energy Company agrees with the violation as stated.
Pursuant to the direction provided in the report, find attached a Reply to the Notice of Violation.
The corrective actions taken and proposed are intended to address the concerns expressed by the NRC inspectors, and to prevent recurrence of similar events.
pladL Kenneth Site General Manager cc: Administrator, Region III USNRC NRC Resident Inspector - Big Rock Point i NRR Project Manager - OWFN, USNRC ATTACHMENT i h [[ [ N 1b
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CONSUMERS ENERGY COMPANY ' BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 97015 Submitted March 11, 1998 .) .i : j I '
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. REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 97015 ~ During an 'NRC Inspection conducted from December 5,1997, through February 2,1998, one-violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below: Violation ~97015-01 . Technical Specification 6.11 requires, in part, that procedures fbr personne1' radiation protection shall be adhered to fbr all operations involving personnel radiation exposure.
The written pre-job briefing fur Radiation W6rk Request (RWP) No. B982035 and procedure 5.5, " Radiation Work Permit," Revision 12, both instructed workers to monitor dosimetry every 15 minutes when in a high radiation ^ area.
Cdntrary to the above, on January 4,1998, a chemical decontamination worker working under RWP No. B982035 was in a high radiation area (HRA) fbr approximately 55 minutes and did not monitor his dosimetry throughout this time.
This is a Severity Level IV violation (Supplement IV).
Consumers Energy Company agrees with the violation as stated.
The requirement to monitor' dosimetry every 15 minutes when in a high radiation. area resides in Big Rock Point (3RP) Administrative Procedure 5.23, "Herlin Gerin Electronic Dosimetry System," Revision 5.
' I.
Reason for the violation.
The cause for this violation was the failure on the part of the chemical decontamination worker wearing the electronic dosimeter (ED). to read the device every 15 minutes as required by procedure.
Discussion-An investigation of the circumstances surrounding the event provided the following information.
,. On Qanuary 4,1998, at approximately 1530 ho'urs, the chemical decontamination' worker took an ED from the rack and proceeded to access contgol.
In separate interviews with.the individual and the . access control technician, the individual stated that he received .
. ~ / permission to enter from the Management Information System (MIS) (" Authorized to Enter" displayed on the monitor) and the access control technician stated that the MIS reader did not alarm when the individual removed his ED from the reader.
This would indicate that the individual had logged in correctly.
However, both the individual and the technician stated that neither had verified that the ED was set at "0.000" before entering the RCA.
The individual reported to his work location in the chemical decontamination skid area.
After approximately 55 minutes, the i individual proceeded to the contamination control boundary to exit.
While crossing the contamination control boundary and removing his ED, the individual noticed that the ED was on " PAUSE."
The ED had not been checked while in the high radiation area.
He proceeded to access control and reported the condition to the technician on duty.
The technician reported the condition to the Radiation Protection and Environmental Services (RP&ES) Supervisor.
The histogram for the ED in question was performed and it was determined that the ED had remained on " PAUSE," indicating that the individual was not logged into the Management Information System (MIS).
Dose reconstruction, based upon the individual's stay time, measured radiation levels in tlie work area, and comparison with the exposures of co-workers, indicated the individual had received 6 millirem during the period of concern.
The individual's thermoluminiscent dosimeter (TLD) was processed and it was determined that the individual had received a total of 206 millirem for the calendar year.
II.
The corrective steos that have been taken and results achieved 1.
A formal critique was held with the individual involved, Plant Manager, RP&ES Manager (RPM), Project Manager, P.N. Services Project Manager, Chemical Decontamination Shift Manager, and the Shift RP Supervisor.
The Plant Manager counseled the individual and his supervisor on the significance of the event and provided expectations for procedure compliance.
2.
The management team initiated a Radiological Incident Report and administrative 1y restricted the individual's dose to 200 millirem by personal dosimeter until the TLD results were reviewed.
The individual ccmpleted his Big Rock Point assignment January 22,1998, 18 days later.
During that period, he made forty
. > . 1' (40) entries into the RCA without incident.
His total l exposure by TLD for 22 days at BRP in 1998 was 462 millirem.
' III. The corrective steos taken to avoid recurrence.
1.
For the duration of the Chemical Decontamination Project, a written log was used at the access point to the RCA and each individual's ED was required to be read and recorded by the access technician prior to permitting entry.
In addition, ED's were required to be read and logged every 15 minutes in the high radiation area.
2.
Stand downs were conducted by PN Services and the Health Physics Technicians to discuss the event and the lessons learned.
The event was also discussed by the Site General i Manager at an all employee meeting.
IV.
The date when the facility will be in full comoliance.
The facility is currently in full compliance.
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