ML20002C758
| ML20002C758 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/20/1973 |
| From: | Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20002C754 | List: |
| References | |
| NUDOCS 8101100825 | |
| Download: ML20002C758 (4) | |
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c.n... ome.. min w.. u.c...n A.no.. s.c..on, u.cn...n moi. Ar.. coo. ei7 vas os so November 20, 1973 Mr. James G. Keppler Re: Docket 50-155 Directorate of Regulatory Operations License DPR 6 Region III US Atomic Energy Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Keppler:
Your letter of October 29, 1973 stated that certain of our activities under Operating License DPR 6 appeared to be in non-compliance with AEC requirements.
Specifically, you state that the criticality monitor alarm set points have been set et greater than 20 millirem per hour on several occasions which exceeds the limit established in 10 CFR 70.2h(a)(1).
Our letter of October 2, 1973 to the Directorate of Licensing acknowledged that it is necessary to raise the alarm set point above the value established in 10 CFR 70.2h(a)(1) during cer-thin plant evolutions other than normal fuel handling to avoid spurious alarms. This letter was written after Mr. L. J. Hueter of your staff pointed out the apparent conflict between the regula-tion and our operations and requested exemption from the regulation during plant evolutions that would cause spurious alams. The letter also stated that we were implementin6 tighter administrative control of these set point changes. One of the objectives of the tighter administrative controls is to ensure that the set point is returned promptly to its normal setting after the high background is removed.
These administrative controls have been implemented on an interim basis and vill remain effective until the exe=ption discussed in the following paragraph is received.
Beeed on recent discussions with the Directorate of Licensing personnel, we '>elieve the exemption, when granted, will eliminate the criticality monitor alam maximum set point value (20 mrem /h).
This vill allow the alarms to be set at higher values and sould eliminate the need for changing the set points when handling mate- '~ rials that raise the background radiation levels. NOV 2 3 1973 fio flo of 25~
~ Mr. Jensa G. Kipplar 2 Docket 50-155 License DPR-6 November 20, 1973 The monitor mounted on the steam dru= cavity wall vill be relocated closer to the new fuel storage to increase its sensitivity. This vill allow a higher alarm setting, thus more margin with regard to spurious alarms. This facility change is scheduled to he co=- pleted by the end of the year. We believe that timely corrective action was initiated thortly after Mr. Hueter's visit. Full compliance vill be achieved when the exemption discussed above is issued. We do not believe that this violation should be considered of Category II severity. On October 12, 1973 the AEC gave notice in the Federal Register that it is considering amending 10 CFR 70.2h. The proposed amendments eliminate the specific alarm set point require =ents. The alarm set points at Big Rock Point have always been vell within those required for detection of the accidental criticality condition pre-scribed by the propored regulation. It is our opinion that the new rcgulations, if enacted, vill not cause in increased risk to the health and safety of plant employees, the public, the common defense and se-curity or the environ =ent. Therefore, we believe this violation should be classed as Category III (procedural). Your letter also refers to "... breakdown in administrative controls..." and requests that we discuss those actions taken to in-prove the effectivenss of our Management controls as they relate to the radiological protection program at Big Rock Point. The event de-scribed in the inspection report is inaccurate, probably because of a note that was annotated to the radiation protection log in the wrong place and the failure of our personnel to adequately co=municate with Mr. Hueter during his inspection. Actually, there vere two separate events which occurred 12 days apart which have been combined into one in Mr. Hueter's report. These events are reviewed in the following paragraphs. Corrective action taken is also included. At 0237, March 8, 1973, the reactor level continuous air monitor (CAM) increased to h500 cpm and the CAM at the personnel lock increased to 2500 cpm. Both CAMS are set for an alert signal by means of a flashing red light and a pulsed ringing bell at 3300 cpm which corresponds to one-half RCG based on I-131. The second alarm at both CAMS is set at 13,000 cpm which corresponds to 2 RCG based on routine calibration with simula'?d I-131. At 02h5, personnel (about h) vorking on the reactor level were given half masks to wear. The half masks were on the ' reactor level since it is normal procedure to have respiratory equipment readily available while sipping fuel.
( ~ Mr. Jemet G. 3 Docket 50-155 License DPR-6 November 20, 1973 A "Hi-Vol" particulate and carbon filter was used to sample the air activity on the reactor level at 0250. An immediate gross B-y count of the particulate filter indicated a level of 5 x 10-9 pCi/cc. Based on this analysis, all personnel were removed from the contain.: lent sphere at 0300 until a spectrum analysis of both particulate and carbon filters was co=pleted. Spectrum analysis of the particulate filter showed mainly I-131 vith small enounts of Cs-13h and Cs-137 The carbon filter was spectrum-analyzed at 0305 and showed Xe-133 and I-131. It was deter-mined at thtt time that the increase in air activity was a result of the fuel sipping operation. (Bundle F-26 had been sipped and the CM4 rise coincided with the lid being rc=oved from the sipper can.) Based on the carbon filter spectrum and the fact that the reactor level and personnel lock CAMS had peaked at 5200 and 3900 cpm, respectively, and were decreasing, containment access was allowed with half masks. Op-erations on the reactor level resumed at approximately 0h30. It should be noted that the CM4s did not reach RCG 1evels for I-131. tillation vell counte" gave 195 x 10 gf the carbon filter in the scin-At Oh50, gress gamma counts pCi/cc, assuming all of the ac-tivity was I-131. RCG value for I-131 is 9 x 10-9 pCi/cc and with a protection factor i 10 (has since been changed to 5) for half masks, the value then becomes 9 x 10-0 pCi/cc. At approximately 0530, the reactor Cm4 reading declined to the normal level of 800 cpm at which time personnel in containment were allowed to remove their half mask status. Based on our review of this incident,' ve have. concluded tilat appropriate action was taken by radiation protection personnel and no further follow-up is required. The second incident occurred at approximately 0115 on March 20, 1973. Two region repaimen were repairing the recirculating pump motor in Room hhb. The Maintenancs Supervisor left the area for a brief period of time during which time one of the repaimen used an air hose in Roca hhh to blev dirt out of the motor. The reactor level and personnel lock CAMS increased to a maximum of 5000 and 8000 cpm, respectively. The senior technician advanced the filter tapes on both CAMS and the counts declined immediately to the nomal range of 700-900 epm. Both repaimen had minor conta=ination on their faces and hair which was removed with a shower.,No work stoppage resulted from the air activity increase. The activity release was of a short duration. At.0200, a par-J ticulate air sample gave 1.5 x 10-10 pCi/ce. j
V-s' l Mr. James-G. D ppler k Docket 50-155 License DPR-6 November 20, 1973 Radiation Protection Procedures were followed with the ex-ception of using co= pressed air to clean contaminated equipment. This situation vill be, resolved by placing proper signs by air outlets in all controlled areas. Yours v'ery truly, I Ralph B. Sewell (Signed) RBS/ce Ralph B. Sewell Nuclear Licensing Ad=inistrator e e e e 6 4 4 = O S e 4 0 + -.}}