ML18068A307

Submits Response to Violations Noted in Insp Rept 50-255/97-16.Corrective Actions:Operations Crews Have Been Briefed Concerning Event & Potential Impact of Operator Actions on Radiological Conditions

ML18068A307
Person / Time
Site:	Palisades
Issue date:	03/04/1998
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-97-16, NUDOCS 9803120348
Download: ML18068A307 (5)

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A CMS Energy Company Palisades Nuclear Plant Tel: 616 164 2296 27780 Blue Star Memorial Highway F{JX: 616 164 2425 Covert. Ml 49043 Tlloma* J. hlmlNao Site Vice President March 4, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE PPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO.

50:-255/97Q16, FAILURE TO POST HIGH RADIATION AREA NRC Radiation Protection Inspection Report No. 50-255/97016 contains a Notice of Violation (NOV) regarding the failure to post a high radiation area. The Consumers Energy Company reply to the violation is included in the Attachment to this letter.

Consumers Energy accepts this violation and agrees that a high radiation area existed without the posting required by 10 CFR 20.1902(b) and Technical Specification 6.7.1.

An additional concern regarding problems which were identified with the post accident sampling system was expressed in the cover letter for the inspection report. That concern is being addressed in a separate submittal. I I I

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SUMMARY

0-F COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

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Thomas J. Palmisano Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255/97016 FAILURE TO POST HIGH RADIATION AREA 2 Pages

REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255197016 FAILURE TO POST HIGH RADIATION AREA NRC NOTICE OF VIOLATION During an NRG inspection conducted December 15-19, 1997, and January 14-16, 1998, a violation of NRG requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR Part 20. 1902(b) requires that the licensee post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, HIGH RAD/A TION AREA" or "DANGER, HIGH RAD/A TION AREA".

Pursuant to 10 CFR 20. 1003 a high radiation area means an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 100 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

Contrary to the above, from approximately 12:30 p.m. to 3:00 p.m. on January 7, 1998, the high radiation area in the Waste Gas Surge Tank Room, with radiation dose rates of up to 120 millirem in an hour at 30 centimeters from the Waste Gas Surge Tank, was not conspicuously posted with a sign bearing the radiation symbol and the words "CAUTION, HIGH RAD/A TION AREA", or "DANGER, HIGH RAD/A TION AREA".

This is a Severity Level IV violation.

CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy agrees that a high radiation area (HRA) existed without the posting required by 10 CFR 20.1902(b) and Technical Specification 6.7.1.

Background

The following describes the conditions, as determined by our investigation:

The Volume Control Tank (VCT) venting that occurred on January 7, 1998, was not a planned evolution. The venting was an operational activity to maintain the VCT press_ure band between 21 to 28 psig as required in System Operating Procedure *

(SOP) 2A. The on-shift Control Room Operators determined the need for VCT venting and promptly performed that activity without first considering the radiological effect in the area of the Waste Gas Surge Tank (WGST). Consequently, there were no advance opportunities for this evolution to be discussed with Health Physics.

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• J REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255/97016 FAILURE TO POST HIGH RADIATION AREA The duration of this unpasted and uncontrolled HRA was from 1235 to 1400, based on the time interval from when Control Room Operators began venting the VCT until the HP Technician arrived at the Waste Gas Surge Tank (WGST) and controlled the area.

Reasons for Violation Our evaluation has identified the root cause to be a lack of operator sensitivity to the impact of their actions on radiological conditions resulting from venting the VCT.

Additionally, when the WGST room was down-posted on May 27, 1997, to a Radiation

• Area (RA), C&RS personnel did not question whether operational events could result in potential HRAs.

Corrective Action Taken and Results Achieved

1. Operations crews have been briefed concerning this event and the potential impact of operator actions on radiological conditions.

2. HP Technicians immediately determined radiation levels in the WGST room and posted the area as a HRA. This event was reviewed by HP Technicians during their weekly meetings and by written communication. The event and the root causes

.were also used as .a case study in discussions with C&RS personnel.

3. C&RS reviewed other areas that have been down-posted from a HRA and determined that no other similar situations exist.

• The result of these actions is that HP and Operations personnel are more aware of the radiological impact of operator actions when venting the VCT.

Corrective Actions Remaining to Avoid Further Violations None Date Full Compliance Will Be Achieved Full compliance was achieved on January 7, 1998, when the area was posted as a HRA.

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