ML19321A491
| ML19321A491 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/18/1980 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8007230516 | |
| Download: ML19321A491 (8) | |
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July 18, 1980 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Cc= mission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCIGT 50-155 - LICENSE DPR BIG RCCK POINT PLANT - RES?CNSE T HEALTH PHYSICS APPRAISAL Sy NRC letter dated June 13, 1980, Consu=ers Power Ccmpany received the results of a Health Physics Appraisal, Inspecticn Report No 80-Oh, performed en March 3-lk, 1980. Consu=ers Power Cc pany's respense to two (2) violations and eight (8) find-ings was requested.
At the request of Consumers ?cver Cc=pany a ten (10) day extension for response was granted by L R Greger, Region III to D ? Hoffman, CPCo on July 8, 1980. The attach-ed enclosure provides Const=ers Power Ccepany's response to the violations and find-ings.
D*,vid ? Ecff=an (Signed)
David ? Hoffnan Nuclear Licensing Ad- %istrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Inforce::. ant NRC Resident Inspector, Big Rock Point h\\
8007230 6 fo
CONSINERS POWER COMPANY Big Rock Point Plant Health Physics Appreisal Docket 50-155 License DPR-6 At the request of the Commission and pursuant to the Atomic Energy Act of 195h and the Energy Reorganisation' Act of 197h, as amended, and the Co= missions's Rules and Regulations thereunder, Consumers Power Company submits our respense to a request for response, dated June 13, 1980, entitled " Health Physics Appraisal".
Consumers Power Company's response is dated July 18, 1980.
CONSU'G S POWER COMPANY By R C Youngdahl (Sirned)
R C Youngdahl, Executive Vice President Sworn and subscribed to before me this 18th day of July 1980.
Dorothy H 3artkus (Siened)
(SD.L)
Dorothy H 3artkus, Notary Public Jackson County, Michigan My conmission expires March 26, 1983
=
CONSUMERS POWER COMPANY BIG ROCK POINT PLANT RESPCNSE TO HEALTH PHYSICS APPRAISAL DATED JUNE 13, 1980 L
The' following is our response to the " Notice of Violation" contained as Appendix 3 and the "Significant Appraisal Pindings" contained as Appendix A in your letter of June 13, 1980, transmitting the results of your health physics appraisal of the Big Rock Point Nuclear Plant.
A_gpendix 3 - Notice of Violations Violation Item #1 3-Technical Specification 10.6.2.2(d) requires that an individual qualified in radiation protection procedures chall be onsite when fuel is in the reactor.
The criteria required to be satisfied b' individuals qualified in radiation protection procedures were-forwarded in a letter from Ziemann (NRC) to 31xel (CPCo) dated March 15, 1977.
Contrary to the above, off-shift radiation protection coverage is routinely provided by_ the shift.superrisors, who typically are not qualified to conduct special and routine contamination and airborne radioactivity surreys and evaluating the results of such surteys.
Restense Consumers Power Company does not believe this to be a valid infraction. Techni-cal Specification 10.6.2.2(d) was issued well before the letter was forwarded from D L Ziemann to D A Bixel dated March 15, 1977 That letter constituted a change in the Technical Specification interpretation. Consumers Power contends the Technical-Specification is satisfied by the qualifications maintained by the shift supertisor (SS). The Big Rock Point Plant Administrative Precedures docuunt the responsibilities of the SS with respect to radiation protection coverage.
The previously accepted practice satisfying this Technical Specification by relying on both the on-shift supertisor who is trained in health physics l
. procedures-through the RO/SRO training programs and censequent licensing by the US NRC and the on-shift operators who are trained in health physics procedures through the 30 training program and also licensed by the US NRC will be continued.
In addition, all on-shift operaters, the shift supertisor and the -
shift technical advisor vill continue to be trained at the plant for RWP exempt status.
However, in view of our concer:: for maintaining a current and high quality radiation protection program at Big Rock Point, Censu=ers Power Company vill
- proceed with the' establishment of a'new superrisory training position at the plant.' The individual filling.this positien vill be responsible for upg-aded radiation protection training of the plant staff.
"'he training
- program will be fully i=plemented by-January 1,1981, and vill include, for RWP exempt personnel, training in all six criteria for individuals qualified for_ radiation protection procedures contained in D L Zie: ann's letter of March 15,1977, to Consu=ers Power Company. Under this progra= additional L detailed training in radiological evaluations, particularly for offsite
' dose consequences under abnormal conditions, vill be provided to the shift
~ technics 1 advisors. Also, a careful screening of the need for RWP-exe=pt status will be undertaken to =inisi::e its use to individuals trray in need of an RWP-exemption.
s
0 CPCo Big Rock Point Plant Response to Health Physics Appraisal 2
dated June 13, 1980 During routine operation of the plant, the non-day shift complement consists of only six employees. Because of the small number of people, work force radiation protection control during nor=al operations or during the initial stages of an emergency by the shift supervisor is a relatively easily managed task. However, when the work in radiologically controlled areas involves non-RWP-exempt pr sonnel such as maintenance personnel during off-shift hours, it will continue to be accomplished with coverage by radiation protection technicians.
In addition, when verk off-shift, while fuel is in the reactor, requires the use of more than two people _in a radiologically controlled area that are not part of the normal shift complement, radiation protection technician coverage vill be provided. We believe with these additional steps that the shift supervisor vill remain fully qualified in radiation protection procedures to satisfy Technical Specificatien 10.6.2.2(d) to assure ecmpetent radiation protection coverage while fuel is in the reactor.
Violation Item #2 10 CFR 20.203(c)(2) requires that high radiation areas be equipped with control devices, which reduce radiation levels or provide audible warning of the levels, or be maintained locked.
Contrary to the above, high radiation areas existed in the condensate de=inera-li:er room and in the vicinity of the turbine =oisture separator at the ti=e of this appraisal but the areas were not locked er equipped with control devices.
An additional area, surrounding the spent fuel pool seek filter tank, becomes a high radiation area for short periods due to activity buildup on the filters.
Although not a high radiatica area during this appraisal, the area is not equip-ped with a control device or locked when high radiation levels exist.
Response
Consumers Power Ccepany ackncvledges the absence of locks for the high radiation areas in the condensate desineralizer room and in the vicinity of the turbine
=oisture separator.
To correct this infraction, Consu=ers Power Co=pany is co==itting to the following:
1.
"'he turbine area is now a locked and alarmed high radiation area.
2.
The entrance to the condensate de=ineralizer is presently chain locked and vill be provided with a locked door by January 1,1981.
i 3
S e fuel pool filter area is presently chain locked.
h.
In order to assure that the area i==ediately above the fuel pool filter does not become a high radiation area, precedural controls vill be instituted i==ediately to change the filter elements before this area
- becomes a high radiation :ene. Such procedural controls =ay also be acceptable for the fuel pool filter area.
5 If the - fuel pool filter area, even with these procedural controls, becc=es a high radiation area en a periodic basis, it vill be provided with a locked door.
a
CPCo Big Rock Point Plant Response to Health Physics Appraisal 3
dated June 13, 1980 Accendix A - Significant Appraisal Findings Although these "Significant Appraisal Findings" are not in violation of Federal Regulations, Consumers Power Company will proceed with the following to main-tain and improve the radiation protection program at Big Rock Point.
1.
Finding Technician and professional staffing within the Chemistry and Radiation Protection Oepartment is not sufficient to allow adequate training of personnel, to provide reasonable acsurance that person-'el loss vill not adversely affect essential Chemistr/ and Radiation Protection Department functions, and to allow adequate performance of assigned responsibilities under routine and anticipated nonroutine conditions (Section 3.b).
Response
Consumers Power Company is proceeding with the establishment of an addi-tional professional position most likely within the Chemistry and Radiation Protection Department. This individual vill be responsible for i= proving and maintaining the training, L*F-exempt and ALARA programs.
Consumers Power Company is also actively seeking tvc Radiation Protection Technicisns to fill a new authorized complement of eight (8) people. This vill allow the adequate performance of assigned responsibilities under rcutine and anticipated nonroutine conditions.
The additional professional position is expected to be filled by Januar/1, 1981, depending on the availability and qualifications of applicants.
2.
Finding Off-shift radiation protection coverage requires upgrading to assure that necessarf measurements can be made and actions taken in accident or other anomalous situations to evaluate radiological hazards and effect appropri-ate radiological precautions. The individuals providing this coverage must not be assigned other duties under the emergency organization which detract from their primary responsibility for radiation protection coverage (Section 3.s).
Restonse As noted in Consumers Power Co=pany respense to Notice of Violation Nn
- 1, the licensee is not aware of any situatien or event during the 18 year operating experience of this facility that eculd not be handled by 57-exe=pt personnel. Furthermore, the licensee shares the audit team's con-cern with regard to availability of training time, recent technician turn-over, vorkloads and availability of qualified people available for filling r
the currently authorized but unfilled technician positions. Off-shift coverage vould versen the situation with respect to these other concerns.
Furthermore, it would li=it severely the licensee's ability to provide adequate maintenance support (L'P processing, direct coverage and, job valuationa, etc), during the nor=al (daytime) =aintenance shift.
-However, plant management currently is reviewing a number of alternatives
CPCO Big Rock Point Plant Response to Health Physics Appraisal h
dated June 13, 1980 for maintaining responsiveness to increased regulatory - equire=ents in all phases of plant operation.
3.
Finding The ALARA program requires significant i=provement, expecially in the areas of program formalization and Chemistry and Radiation Protection staff authority (Sections 3.c and 10).
Restonse See Consu=ers Power Company response to Finding #1 of Appendix A above.
In addition corporate manage =ent agrees with the desirability of additional formalization and company-wide unifo mity in certain significant aspects of ALARA policy. Such corporate policy currently is in draft form and is expected to be issued by the end of 1980. This policy will also address the authority of the Radiation Protection L part=ent including the ability to enforce radiation protection procedures and stopping work on, jobs believed to be radiologically hazardous.
k.
Finding The training program requires significant i= prove =ent, especially in the areas of Chemistry and Radiation Protection Technician training and R'4P-4 exe=pt training (Sections h.a and b, and 12.a).
Response
Desirability for i= prove =ent is acknowledged. See Consu=ers Power Cc=pany response to Finding #1 above..
5 Finding The R'4F-exe=pt progras, in its present for=, has significant weaknesses in training of personnel and in basic femat (Sectiens h.b and 8.b).
Respense This program is expected to be strengthened by establishment of an additional professional position. See Consu=ers Fever Cc=pany response to Finding #1 and Violation #1 above.
6.
Finding Perscnal contamination =onitoring practices require significant i= prove-nent in the areas of equip =ent sensitivities, for=al procedures describ-ing _ equipment calibratiens and alam setpcints, and enforce =ent of pro-cedures for use of perscnal conta=ination equi;=ent (Sections 3.c and 9.e and d).
Response
The i= proved training program as a result of the additicnal professicnal assistance vill prc=cte a better understanding of radiation protection procedures ani =itigate the need for additional enforcement action.
CPCo Big Rock Point Plant Response to Health Physics Appraisal 5
dated June 13, 1980 The plant staff are currently evaluating a new portal monitor with better sensitivity and shorter count time. The evaluation and possible purchase and installation of this monitor should be complete by January 30, 1981.
Proper frisker use vill also be emphasized in the improved training program to maintain radiation exposure ALARA along with an evaluation of frisker sensitivity and relocation to lover noise and radiation background areas.
Formal procedures will be developed describing equipment calibrations and alarm setpoints where necessary.
7.
Finding Airborne effluent controls require i=provements in noble gas quantification methods, laboratory ventilation release deter =1 nations, and EEPA filter changeout and testing criteria (Section 11.b).
Response
A high range monitor was added to monitor the noble gas effluents at the stack to satisfy the interim requirements of NUREG-0578. A response versus activity curve was developed for this monitor to quantify noble gas releases.
By January 1, 1981, a study and analysis will be cenpleted on stack gas ssn-ples to deter =ine that the present stack gas conitor quantifies noble gas release rates appropriate and that the off-gas is the overwhelming centribu-tion to total release. A germanium detector coupled to a multichannel analy-sis system is being designed to satisfy the long-term requirements of NUREG-0578. This system will be operational according to the NRC-defined schedule.
Monthly surveillance by contamination survey on the laboratory exhaust fan duct vill be implemented by September 1, 1980. All HEPA filters vill be scheduled for changecut and/or sa=pling to determine if changeout is neces-sary on a routine basis. This echeduling is expected to occur by January 1, 1981.
~
8.
Finding Although not indicative of broad problem areas, significant weaknesses requiring corrective actions vere identified in the following areas:
A.
High radiation area access centrol (Section 3.d) 3.
Supply of stand-off (extending probe), high range survey instruments and survey instrunent operability checks before use (Section 9.2)
C.
Procedure coverage and adherence (Section 6)
D.
Te=porary storage of low-level radioactive trash (Section ll.c)
Response
Consumers Power Co=pany is currently evaluating these areas for possible i=provement. The folleving provides our objectives in relation to the above ite=s:
A.
High radiation area access centrol is addressed by the response to
. Violation Item #2 above.
3.
2 valuation and recc=nendatica for purchase of additional radiation protection instru=ents will be ec=pleted by Septe=ber 1,1980.
5 CPCo Big Rock Point Plant Respcuse to Health Physics Appraisal 6
dated June 13, 1980 C..The training program vill emphasice radiation protection procedure adherence in accordance with the responses to Violation Item #1 and applicable findings.
D.
Temporary storage of low-level radioactive trash will be improved by establishment of procedural centrols in the form of bag limits or container storage. These controls vill be established by September 1, 1980.
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