ML19321A636
| ML19321A636 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/13/1980 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML19321A637 | List: |
| References | |
| NUDOCS 8007240004 | |
| Download: ML19321A636 (5) | |
See also: IR 05000155/1980004
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Docket No. 50-155
Consumers Power Company
ATTN:
Mr. R. B. DeWitt
Vice President
Nuclear Operations
212 West Michigan Avenue
Jackson, MI 49201
Gentlemen:
Subject: Health Physics Appraisal
The NRC has identified a need for licensees to strengthen the health
physics programs at nuclear power plants and has undertaken a signif-
icant effort to ensure that action is taken in this regard. As a
first step in this effort, the Office of Inspection and Enforcement is
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conducting special team appraisals of the health physics programs, in-
cluding the health physics aspects of radioactive waste management and
onsite emergency preparedness, at all operating power reactor sites.
The objectives of these appraisals are to evaluate the overall adequacy
and effectiveness of the health physics program at each site and to
identify areas of weakness that need to be strengthened. We will use
the findings from these appraisals as a basis not only for requesting
individual licensee action to correct deficiencies and effect improve-
ments but also to improve NRC requirements and guidance.
This effort
was identified to you in a letter dated January 22, 1980, from Mr.
Victor Stello, Jr., Director, NRC Office of Inspection and Enforcement.
During the period March 3 to March 14, 1980, the NRC conducted the
special appraisal of the health physics program at the Big Rock Point
Nuclear Plant. Areas examined during this appraisal are described in
the enclosed report (50-155/80-04). Within these areas, the appraisal
team reviewed selected procedures and representative records, observed
work practices, interviewed personnel, and performed independent measure-
ments. We request that you carefully review the findings of this report
for consideration in improving your health physics program.
Findings of this appraisal indicate that several significant weaknesses
exist in your health physics program. These include, among others,
staffing levels, training, procedure adherence, personal contamination
control, ALARA formalization, and clarification of the authority delegated
to the Health Physics Organization. These items are set forth in
Appendix A, "Significant Appraisal Findings." Your past performance
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in personal' exposure and radiological effluent controls has been accept-
able but we believe that the identified weaknesses require correction
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to enable you to perform equally well in future normal and offnormal
situations. -Your present health physics program is considered adequate
to support continued operation while achieving acceptabla corrective
action for the identified weaknesses.
We recognize that an explicit regulatory requirement pertaining to each
significant weakness identified in Appendix A may not currently exist.
However, to determine whether adequate protection will be provided for
the health and safety of workers and the public, you are requested to
submit a written statement within twenty (20) days of your receipt of
this letter, describing your corrective action for each significant weak-
ness identified in Appendix A, including:
(1) steps which have been taken;
(2) steps which will be taken; and (3) a schedule for completion of action.
This request is made pursuant to Section 50.54(f) of Part 50, Title 10,
Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities do
not appear to have been conducted in full compliance with NRC requirements,
as set forth in the Notice of Violation enclosed as Appendix B.
The items
of noncompliance in Appendix B have been categorized into the levels of
severity as described in our Criteria for Enforcement Action dated December
13, 1974. Section 2.201 of Part 2, Title 10, Code of Federal Regulations,
requires you to submit to this office, within twenty (20) days of your
receipt of this notice, a written statement or explanation in reply, in-
cluding:
(1) corrective steps which have been taken and the results achieved;
(2) corrective etcps which will be taken to avoid further items of non-
compliance; and (3) the date when full compliance will be achieved.
You should be aware that the next step in the NRC effort to strengthen
health physics programs at nuclear power plants will be a requirement
by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop,
submit to the NRC for approval, and implement a Radiation Protection Plan.
Each licensee will be expected to include in the Radiation Protection Plan
sufficient measures to provide lasting corrective action for significant
weaknesses identified during the special appraisal of the current health
physics program. Guidance for the development of this plan will incor-
porate pertinent findings from all special appraisals and will be issued
by NRR in the fall of this year.
In accordance with Section ?. 790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of. Federal Regulations, a copy of this letter and the en-
closures will be placed in the NRC's Public Document Room.
If this material
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contains any information that you believe to be prorarietary, it is
necessary that you make a written application within 20 days to this
office to withhold such information from public discicsure. Any such-
application must be accompanied by an affidavit, executed by the owner
.of the information, which identifies the document or part sought to be
withheld and which contains a statement of reasons which addresses with
specificity the items which will be considered by the Commission as listed
in Subparagraph (B)(4) of Section 2.790.
The information c.ooght to be with-
held shall be incorporated as far as possible into a separate part of the
affidavit. If we do not hear from you in this regard within the specified
period, this letter and the enclosures will be placed in the Public Docu-
ment Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
!
1.
James G. Keppler
Director
Enclosures:
1.
Appendix.A, Significant
Appraisal Findings
2.
Appendix B, hotice of
Violation
3.
IE Inspection Report
No. 50-155/80-04
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cc w/encls:
-Mr. D. P. Hoffman, Nuclear
Licensing Administrator
Mr. C. J. Hartman, Plant
Superintendent
Central Files
Reproduction Unit NRC 20b
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Local PDR
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Ronald Callen, Michigan Public
Service Commission
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Appendix A
SIGNIFICANT APPRAISAL FINDINGS
Consumers Power Company
License No. DPR-6
Based on the Health Physica Appraisal conducted March 3-14, 1980, the
following items appear to require corrective actions.
(Section references
are to the Details portion of the enclosed Inspection Report.)
1.
Technician and professional staffing within the Chemistry and Radia-
tion Protection Department is not sufficient to allow adequate train-
ing of personnel, to provide reasonable assurance that personnel loss
will not adversely affect essential Chemistry and Radiation Protection
Department functions, and to allow adequate performance of assigned
responsibilities under routine and anticipated nonroutine conditions.
(Section 3.b)
2.
Offshift radiation protection (overage requires upgrading to assure
that necessary measurements can be made and actions taken in accident
or other anomalous situations to evaluate radiological hazards and
effect appropriate radiological 9recautions. The individuals provid-
ing this coverage must not be ast igned other duties under the emer-
gency organization which detract from their primary responsibility
for radiation protection coverage.
(Section 3.a)
3.
The /LARA program requires significant improvement, especially in the
areas of program formalization and Chemistry and Radiation Protection
staft authority.
(Sections 3.c and 10)
4.
The training program requires significant improvement, especially in
the areas of Chemistry end Radiation Protection Technician training
and RWP-exempt training.
(Sections 4.a and b, and 12.a)
5.
The RWP-exempt program, in its present form, has significant weak-
nesses in training of personnel and in basic format.
(Sections 4.b
and 8.b)
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Personal contauination monitoring practices require significant
improvement in the areas of equipment sensitivities, formal proce-
dures describing equipment calibrations and alarm setpoints, and
enforcement of procedures for use of personal contamination equip-
ment.
(Sections E.c and 9.c and d)
7.
Airborne effluent controls require improvements in noble gas quanti-
fication methods, laboratory ventilation release determinations, and
HEPA filter changeout and testing criteria.
(Section 11.b)
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Appendix A
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8.
Although not indicative of broad problem areas, significant weak-
nesses requiring corrective actions were identified in the follow-
ing areas:
High radiation area access controls.
(Section 8.d)
Supply of stand-off (extendible probe), high range survey instruments
and survey instrument operability checks before use.
(Section 9.a)
Procedure coverage and adherence.
(Section 6)
Temporary storage of low-level radioactive trash.
(Section 11.c)
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