ML19339B974
| ML19339B974 | |
| 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) |
| Shared Package | |
| ML19339B975 | List: |
| References | |
| NUDOCS 8011100533 | |
| Download: ML19339B974 (8) | |
Text
,,
i 4%Qs t
i f/
% CORSu m 815 l*
U
.b K%;q-y..d Company L
i Generet Offecess 212 West Mech: gen Avenwe.Jochson Michsgen 49201. Area Code 697 7#t8-0S60 i
July 18, 1980 l
1 i
I
)
Mr James G Keppler Office of Inspection and Enforcement 3
Region III l
US Nuclear Regulatory Cor: mission 799 Roosevelt Road Glen'Ellyn, IL 60137 l
DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - RESPONSE TO HEALTH PHYSICS APPPAISAL 1
By NRC letter dated June 13, 1980, Consumers Power Company received the results 1
cf a Health Physics Appraisal, Inspection' Report No 80-Oh, performed on March 3-lh, 1980. Consur.ars Power company's response to two (2) violations and eight (8) find-l ings was requested.
l I
At the request of Consumers Power Company a ten (10) day extension for response was granted by L R Greger, Region III to D P Hoffman, CPCo on July 8, 1980. The attach-ed enclosure provides Consumers Power Ccmpany's response to the violations and find-
+
ings.
David P Hof man (Signed)
David P Hoffhan j
Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector, Big Rock Point l
i b
l
~~
l l
JUL 211.un i
,ewa,.
-,v v
s-
--s~-+-
n-
-, r m e e-",,
- -.. ~ -
e n
'w'~wr' w'=Y'
C0!!SUYERS PO'4ER COMPA'iY Big Rock Point Plant Health Physics Arrraisal Docket 50-155 License DPR-6 At the request of the Co==ission and pursuant to the Atomic Energy Act of 195h and the Energy Reorganization Act of 197h, as amended, and the commissiens's Rules and Regulations thereunder, Consumers Power Company submits our response to a request for response, dated June 13, 1980, entitled " Health Physics Appraisal".
Consumers Power Company's response is dated July 18, 1980.
CO:iSU'G S POWER COMPA?iY By R C Younedahl (Sirned)
R C Youngdahl, Executive Vice President Sworn and subscribed to before me this 18th day of July 1980.
Dorothy H Bartkus (Signed)
(SEAL)
Dorothy H Barthus, Notary Public Jackson County, Michigan My conmission expires March 26, 1983.
i
. CONSUMERS POWER COMPANY BIG ROCK POINT PLANT RESPONSE TO HEALTH PHYSICS APPRAISAL DATED JUNE 13, 1980
~
The following is our response to the " Notice of Violation" contained as Appendix B and the "Significant Appraisal Findings" 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.
1 Anvendix B - Notice of Violations Violation Item #1 Technical Specification 10.6.2.2(d) requires that an individual qualified in radiation protection procedures shall be onsite when fuel is in the reactor.
The criteria required to be satisfied by individuals qualified in radiation protection procedures were forwarded in a letter from Ziemann (NRC) to Bixel (CPCo) dated March 15, 1977 j_
Contrary to the above, off-s;.ift radiation protection coverage is routinely provided by the shift supervisors, who typically are not qualified to conduct special and routine contamination and airborne radicactivity surveys and evaluating the results of such surveys.
Resoonse 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 supervisor (SS). The Big Rock Point Plant Administrative Procedures document 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 supervisor who is trained in health physics i
procedures through the RO/SR0 training programs and consequent licensing by the US NRC and the on-shift operators who are trained in health physics procedures through the RO training program and also licensed by the US NRC will be continued.. In addition, all on-chift operators, the shift supervisor and the i
shift technical advisor vill continue to be trained at the plant for RWP exempt status.
i However, in view of our concern for maintaining a current and high quality radiation protection program at Big Rock Point, Consumers Power Company vill proceed with the establishment of a new supervisory training position at i
the plant. The individual filling this position vill be responsible for
- ~
upgraded radiation protection training of the plant staff. The training j
program vill be fully implemented by January 1,1981, and vill include, for i
RWP exe=pt personnel, training in all six criteria for individuals qualified for radiation protection procedures contained in D L Ziemann's letter of March 15, 1977, to Consumers Power Company. Under this program additional detailed training in radiological evaluations, particularly for offsite l
. dose consequences under abnormal conditions, vill be providri to the shift technical advisors. Also, a careful screening of the.need for RWP-exempt status vill be undertaken to minimise its use to individuals truly in need of an RWP-exe ption.
r-i%e
--.e m.
-p
-==rw
.y.y ep,f..y7.
-. +,
,w T'
~ + ' - - '
-T"'"'""
~
CPCo Big Rock Point Plant Response to Health Physics Appraisal 2
o 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 normal 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 personnel such as maintenance personnel during off-shift hours, it vill continue to be accomplished with coverage by radiation protection technicians.
In addition, when work 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 co=plement, radiation protection technician coverage vill be provided. We believe with these additional steps that the shift supervisor will remain fully qualified in radiation protection procedures to satisfy Technical Specification 10.6.2.2(d) to assure co=petent 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.
Contra y to the above, high radiatien areas existed in the condensate deminera-lizer room and in the vicinity of the turbine moisture separator at the time of this appreisal but the areas were not locked or equipped with control devices.
An additional area, surrounding the spent fuel pool sock filter tank, becomes a high radiation area for short periods due to activity buildup on the filters.
Although not a high radiation area during this appraisal, the area is not equip-ped with a control device or locked when high radiation levels exist.
Restense Consumers Power Company ackncvledges the absence of locks for the high radiation areas in the condensate de ineralizer room and in the vicinity of the turbine noisture separator.
To correct this infraction, Consumers Power Company is committing to the following:
Thetbrbineareaisnowalockedandalarmedhighradiationarea.
1.
2.
The entrance to the condensate demineralizer is presently chain locked and vill be'provided with a locked door by January 1,1981.
3.
The fuel pool filter area is presently chain locked.
h.
In order to assure that the area immediately above the fuel pool filter does not become a high radiation area, procedural controls vill be instituted i==ediately to change the filter elements before this area becomes a high radiation zone. Such procedural controls may also be acceptable for the fuel pool filter area.
5.
If the fuel pool filter area, even with these procedural controls, becomes a high radiation area,on a periodic basis, it vill be provided with a locked door.
CPCo Big Rock Point Plant Response to Health Physics Appraisal 3
dated June 13, 1980 Aprendix A - Sirnificant Aunraisal Findings Although these "Significant Appraisal Findings" are not in violation of Federal Regulations, Consumers Power Company vill proceed with the following to main-tain and improve the radiation protection progra= at Big Rock Point.
1.
Finding Technician and professional staffing within the Chemistry and Radiation Protection Department is not sufficient to allow adequate training of personnel, to provide reasenable 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).
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 improving and maintaining the training, RWP-exempt and ALARA programs.
Consumers Power Co=pany is also actively seeking two Radiation Protection Technicians to fill a new authorized complement of eight (8) people. This vill allow the adequate performance of assigned responsibilities under routine and anticipated nonroutine conditions.
The additional professional position is expected to be filled by January 1, 1981, depending on the availability and qualifications of applicants.
2.
Finding Off-shift radiation protection coverage 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 appropri-ato 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.a).
Resconse As noted in Consu=ers Power Cc=pany respense to Notice of Violation Ite
- 1, the licensee is not aware of any situation or event during the 18 year operating experience of this facility that could not be handled by RWP-exempt personnel. Further=cre, the licensee shares the audit team's cen-cern with regard to availability of training time, recent technician turn-over, workloads and availability of qualified people available for filling the currently authorized but unfilled technician pcsitions. Off-shift coverage vould vorsen the situation with respect to these other concerns.
Furthermore, it would limit severely the licensee's ability to provide adequate =aintenance support (RWP processing, direct coverage and job evaluations, etc), during the normal (daytime) raintenance shift.
However, plant management currently is reviewing a nu=ter of alternatives
CPC0 Big Rock Point Plant Response to Health Physics Appraisal h
_ dated June 13, 1980 for maintaining responsiveness to increased regulatory requirements in all phases of plant operation.
3.
Finding The ALARA program requires significant improvement, expecially in the areas of program formalization and Chemistry and Radiation Protection staff authority (Sections 3.e and 10).
Respense See Consumers Power Company response to Finding #1 of Appendix A above.
In addition corporate management agrees with the desirability of additional for:alization and company-wide uniformity in certain significant aspects of ALARA policy. Such corporate policy currently is in draft fons and is expected to be issued by the end of 1980. This policy vill also address the authority of the Radiation Protection Department including the ability to enforce radiation protection procedures and stopping work on jobs believed to be radiologically hazardous.
h.
Finding The training progra= requires significant improvement, especially in the areas of Chemistry and Radiation Protection Technician training and RWP-exempt training (Sections h.a and b, and 12.a).
Restonse Desirability for improvement is acknowledged. See Consumers Pover Company response to Finding #1 above.
5 Finding The RWP-exempt program, in its present form, has significant weaknesses in training of personnel and in baric format (Sections h.b and 8.b).
Resronse This program is expected to be strengthened by establishment of an additional professional position. See Consumers Power Company response to Finding #1 and Violation #1, above.
6.
Finding Personal contamination monitoring practices require significant improve-ment in the areas of equipment sensitivities, formal procedures describ-ing equip =ent calibratiens and alarm setpoints, and enforcement of pro-cedures for use of personal contamination equipment (Sections 8.c and 9.c and d).
Response
The improved training program as a result of the additional professional assistance vill prcmote a better understanding of radiation protection procedures and mitigate 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 improvements in noble gas quantification methods, labcratory ventilation release determinations, and HEPA filter changeout and testing criteria (Section 11.b).
Response
A high range monitor was added to moniter the noble gas effluents at the stack to satisfy the interim requirements of NUREG-05 T8. A response versus activity curve was developed for this monitor to quantify noble gas releases.
By January 1, 1981, a study and analysis vill be completed on stack gas sen-ples to determine that the present stack gas monitor quantifies noble gas release rates appropriate and taat the off-gas is the overwhelming contribu-tion to total release. A germanium detector coupled to a multichannel analy-sis system is being designed to satisfy the long-term recuirements of NUREG-0578. This system vill 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 chsngeout and/or sampling to determine if changeout is neces-sary on a routine basis. This scheduling is expected to occur by January 1, 1961.
8.
FindEnc Although not indicative of broad problem areas, significant weaknesses requiring corrective actions were identified in the following areas:
A.
High radiation area access control (Section 8.d)
~
B.
Supply of stand-off (extending probe), high range survey instruments and survey instrument operability checks before use (Section 9.2)
C.
Procedure coverage and adherence (Section 6)
L.
Temporary storage of low-level radioactive trash (Section 11.c)
Response
Consumers Power Company is currently evaluating these areas for possible improvement. The following provides our objectives in relation to the above items:
A.
High radiation area access control is addressed by the response to Violation Item #2 above.
B.
Evaluation and reco==endation for purchase of additienal radiation protection instruments vill be ecmpleted by September 1, 1980.
CPCo Big Rock Point Plant Response to Health Physics Appraisal 6
dated June 13, 1980 9
C.
The training program vill emphasize radiation protection procedure adherence in accordance with the responses to Violation Item #1 and applicable findings.
D.
Te=porary storage of low-level radioactive trash will be improved by establishment of procedural controls in the form of bag limits or container storage. These controls vill be established by September 1, 1980.
O o
e