ML18057A705
| ML18057A705 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/14/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9101240015 | |
| Download: ML18057A705 (3) | |
Text
consumers Power POW ERIN&
MICHl&AN~S PRO&RESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 January 14, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
GB Slade General Manager REPLY TO NOTICE OF VIOLATION-FAILURE TO MEET TECHNICAL SPECIFICATION REQUIREMENTS REGARDING HIGH RADIATION AREA ENTRY CONTROL Nuclear Regulatory Commission (NRC) Inspection Report No. 50-255/90019, dated October 5, 1990 identified an apparent violation of Technical Specification 6.12.1.
NRC Notice of Violation dated December 13, 1990 issued a violation for failure to meet Technical Specification requirements regarding high ra_di at ion area entry control.
In accordance with the provisions of 10 CFR 2.201 our response to the notice of violation follows:
Violation 50-255/90019-05 Technical Specification 6.12.1 requires that individuals permitted to enter a high radiation area must be accompanied by a radiation monitoring device which continuously indicates dose rates or by an individual qualified in radiation protection procedures who is equipped with a radiation dose rate device.
Contrary to the above, on December 17, 1989, a Plant Support Supervisor and an Auxiliary Operator entered a posted high radiation area without a radiation monitoring device which continuously indicated dose rates and were not accompanied by an individual who was qualified in radiation protection procedures who possessed a radiation dose rate device.
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2 Reason For Violation On December 7, 1989, a Radwaste Plant Support Supervisor (RPSS) and an Auxiliary Operator (AO) proceeded to the radwaste volume reduction system drum fill area to resolve a drum indexing problem.
These individuals were unaware until they reached the drum fill area that the high radiation area boundary had been moved to the door of the drum fill room.
The AO did not have a meter with him because his detailed turnover, which included a sketch of the area, had indicated that the area was not posted as a high radiation area.
The AO had checked the monitors in the control room for the volume reduction system before proceeding to the drum fill area and noted no abnormal radiation levels.
When the RPSS arrived at the drum fill room and saw the unexpected boundary, he disregarded it for expedience of work and proceeded into the room to correct the drum indexing problem.
The AO, who did not have a radiation survey meter, followed the RPSS across the high radiation area boundary.
The AO knew the requirements for having a radiation survey meter and that he was not qualified to provide radiological coverage.
The AO did not stop the RPSS from entering the area.
The Radiological Services Manager (RSM) observed the individuals in the posted high radiation area during a routine tour of the plant. The RSM did not immediately remove the individuals from the area as stated in the NRC letter dated December 13, 1990, but rather questioned the individuals regarding their compliance with high area radiation requirements shortly after their exiting the area. At this time it was determined that the RPSS was not qualified to provide self monitoring and would have required radiological coverage to be in conformance with the Technical Specifications.
The violation is attributable to an error in judgement on the part of the RPSS who thought he knew the radiological conditions of the area and could safely disregard the boundary.
Even though the volume reduction system was not processing waste at the time, and therefore, the area was not in actuality a high radiation area, the RPSS decision to violate the boundary was wrong and is not condoned by Consumers Power Company.
Corrective Action Taken and Results Achieved A management review board was convened immediately after the event to gather facts and determine appropriate corrective actions.
The individuals involved received disciplinary actions in accordance with Consumers Power Company's disciplinary policy.
Corrective Actions Taken To Avoid Future Non-Compliance The event was discussed with other operations personnel to emphasize the importance of and consequences of failing to comply with requirements.
The volume reduction system drum fill processing sheet was revised to require notification of health physics prior to processing. This will assure better coordination between the posting of the volume reduction system area as a high radiation area and the actual processing of waste.
We believe the event was due to an error in judgement on the part of the
3 individuals involved and that the disciplinary actions and the discussions with the operators have reinforced the Company's policy of strict adherence to policies and procedures.
Date When Full Compliance Will Be Achieved All corrective actions have been completed.
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Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades