ML20148L325
| ML20148L325 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/25/1980 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20148L328 | List: |
| References | |
| NUDOCS 8012090468 | |
| Download: ML20148L325 (2) | |
Text
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g 793 ROOSEVELT ROAD g-GLEN ELLYN, ILLINOIS So137 NOV 2 5 880 MEMORANDUM FOR:
D. M. Crutchfield, Chief, Operating Reactors Branch No. 5, DOL FROM:
James G. Keppler, Director
SUBJECT:
BIG ROCK POINT: OFFSHIIT RADIATION PROTECTION STAFFING In a letter dated November 14, 1980, Consumers Power Company responded to your letter dated September 5,1980, regarding emergency prepared-ness information applicable to the Big Rock Point plant. Your letter had noted a Big Rock Point emergency plan deficiency regarding off-shift staffing of health physics and radiochemistry technicians.
Consume rs Power Company responded that Region III had accepted the addition of a training position to the plant staff "as a satisfactory solution to providing adequate radiation protection off-shift."- That statement is inco rrect.
Our position, as documented in letters to the licensee dated June 13,,1980, August 26, 1980, and September 24, 1980, is that, although our Health Physics Appraisal concluded that the licensee's off-shif t radiation protection coverage needed upgrading, we had no regulatory basis to require off-shift staffing by radiation protection personnel. Our June 13, 1980, letter stated, "The individuals provf ding this coverage (radiation protection) must not be assigned other duties under the emergency organization which -
dutract from their primary responsibility for radiation protection coverage."
Our September 24, 1980, letter stated that "Our position remains... that off-shift radiation protection coverage should be upgraded to ensure i
ef fective accident response."
In addition to the Health Physics Appraisal conclusion that of f-shif t radiation protection coverage needed upgrading, the licensee was cited
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for noncompliance with a technical specification requiremen.t which requires staffing by individuals qualified in radiation protection procedures in accordance with specific criteria forwarded in a letter from NRR (Ziemann) dated March 15, 1977.
Compliance with that require-ment was achieved' by additional training, but -such training did not satisfy the Health Physics Appraisal concern for of f-shif t radiation protection coverage.
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If you have any ques.tions regarding this matter, please contact W. L.
Fishe r o r ' A. B. Davis.
60.[v amesG.KeppleI Director Enclosures :
1.
Consumers Power Company-Itr. dtd. 11/14/80 2.
NRR ltr. dated 9/5/80 3.
RIII ltr. dated 6/13/80 4.
Consumers Power Company itr. dtd. 7/18/80 5.
RIII ler, dated 8/26/80 6.
RIII ltr. dated 9/24/80 cc w/ encl:
H. D. Thomburg A. B. Davis W. L. Fisher Central Files
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consumen power company General OMkaa: 213 west Wiemisen Avenue. Jeckson. Murueen 49201 * (517) 788 0450 November ih, 195C Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Coc=ission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR -
BIG ECCK POINT PLANT - EERCC:CY PLAN SUEMITTALS AND ADDITIONAL INF0FF.ATION AND REQUIRCE!CG In reference to your letter dated September 5,1980 the foll:ving infermation is provided to answer your coments and requests, and to :.eet the requiremente of NUEEG-065L, " Criteria for Preparation and Evaluation of Radiological Emer-gency Plans and Preparedness in Supper of Nuclear ' rver Plants". Revisien 63 to the Big Rock Point Plant Site Energency Plan includes corrections for the deficiencies noted by the staff as indicated below and vill te sutcittci and imSeme..ted by December 1,1930 as agreel up'n with Mr Wa'.. r Drf.ser. Of ycs-staff.
COE CA The letters of agreement with varicus Offsite scencie: hwie L e. upisted 2n; vill be included in Revision 60.
CO!<TC B The 31g Rock Poin: Plant Site Emergency Plan and, in parti:ule.r, the plan's implementing precedures detail all immediate action assignment-in the event of an emergency.
In al* cases we believe the present minimur. shift ecmplement is adequate to satisfy the immediate action needs of Table 5-1 of NUEE3 065L.
For exa=ple, the Site E=ergency tirector is assigned commur;ication respcnsibi-lity and the Auxiliary Operators are assigned radiation monitoring duties pend-ing the arrival of the dedicated com=unicator and chemical and radiation pro-tection techni:ians. Further, neither the plan or its procedures contain any innediate action requirements that can not be performed by onsite personnel.
Eovever, because of our relatively small off-shift complement as referenced by NRC, Region III letter to Consumers Power Company of June 13, 1980 trans=itting the results of your Health Physics Appraisal and our subsequent re.4 pense to Region III of July 18, 1980, Co.'umers Power Company has established a new supervisory training position at lig Rock Point. This individual is responsible, among other things, for providing additional deta'iled training in radiological I
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- Mr Dennis M Crutchfield, Chief 2
Bi'g Rock Paint Plant Novamber ik, 1980 evaluation, particulary for offsite dose consequences under abnors.a1 conditions,
to the existing shift complement. By letter dated September 2L, 1980, Pegion III accepted this additional training position as a satisfactory solution to providing adequate radiatien protection off-shift.
C0tmT C Co rected in Site Energency Flan ?evicien 60.
CC50G C? D No action required at this time.
COMMCC E Cor,rected in Site E=ergency Plan Fevision 60.
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A dedicated line has been installed from Big Rock Point Plar.t to the State On-scer.e Energency Operating Center at the Michigan State Police Post in Petcskey. This is in addition to direct police radio communications.
COMME'E G Public Information Program and News Media infor=ation vil; be incorporated in Site-Imergency Plan Revision 60.
COKC:T H No action required at this time.
CC!0CC I No actier. required at tnis time.
.CCMMINT J Flar.t I:plscentation Procedure Lh assigns a se:urity offic=r to the be2:h tc evacuate any fishermen or other parsens and su=mo.:s tne US 'cs:: Cuard.
CCMCC L No action required.
COMMENT M_
Our present recovery plan is found in Appendix D No 22, " General Office Nucient Emergency Imple=entation Procedure". These procedures vill be submitted, at a later date,as required by KRC schedule.
COMCTT N Exercise and drill information vill be included in Site Emergency Plan Revision 60.
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- Big Rock Point Plant November lh, 1980 COMMDIT 0 Training program information vill be included in Site D:ergency Plan Fevisien 60.
COMMDC P No'ketion required.
David P Hoffman (31gned)
David P Hoffma.n Nuclear Licensing Administrator CC Director, Region III, USNBC NRC Resident Inspector - Big Rock Point e
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September 5, 1980 Docket No. 50-155 N.R.B.DeWitt Vice President Consumers Power Company 1945 Parnell Road Jackson, Michigan 49201
Dear Mr. DeWitt:
The staff has completed its review of your emergency plan submittals dated October 29,1979. March 11,1980, June 9,1980, and June 12, 1980 (Appendix.
M only) which relate to prompt improvement of emergency preparedness.
Your emergency plan was reviewed against the criteria stated in NUREG 0654, " Criteria for Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants."
Our review has indicated that additional information and comitments are required before the staff can conclude that your onsite energency pre-paredness progrem meets the afore-mentioned criteria.
Enclosed is a list of coments.
Your emergency plan should be revised to address C'
these comments and a revision to the plan should be provided to us within 60 days of receipt of this letter.
In cur view, your emergency plan dated June 9,1980 reflects improvement over your existing plan and gives a greater margin for public health and sa fe ty.
Since the revised plan does not downgrade the effectiveness of your emergency preparedness, you should begin to implement this revision.
We would be pleased to discuss or clarify any of the information requested, if you so desire.
Sincerely, b/
% Dennis M. Crutchfield, Chief Operating Reactors Branch f5 Division of Licensing
Enclosure:
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ENCLOSURE i
1 Comments on Big Rock point Emergency Plan The following deficiencies are categorized in NUREG-0554 format.
A.
Assignment of Responsibility (Organization Control)
Written Letters of Agreemert (LOA) with various offsite support agencies are out of date. Tr.e following LOA's from Appendix A of the Site Emergency Plan need to be updated.
Charlevoix Fire Departmr.nt Charlevoix City Hospital Little Traverse City Hospital Emmet County Sheriff's Office United States Coast Guard - Charlevoix Charl evo4x,--MI B.
On%te Emergency Organization x
The plan does not indicate that the minimum shift staffing regulre-ments as per Table B-1 of the criteria will be established. Speci-C fical*iy, only six qualified individuals are available on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day s
basis. They include: one Shift Supervisor; two Control Room Operators; two Auxiliary Operators; and one Shift Technical Advisor.
r,l The following four additional shift positions must be manned on a u
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24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day basis: one Health physics Techician; one Rad /Chen'D-f/
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niciant one dedicated person for notification and communications; an
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one Shift Foreman or equivalent Senior Reactor Operator.
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NEmergency Response Support and Resources 3
The plan identifies radiological laboratories which could be used in t
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Docket No. 50-155
~ do~nsumers 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 conducting special team appraisals of the health physics programs, in-ciuding the health physics aspects of radioactive wa'ste 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., Direc:or, NRC Of fice of Inspection and Enforcement.
l During the period Malen 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-
.l 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 veaknesses exist in your health physics program. These include, among others, a
staffing levels, training, procedure adherence, personal contamication l
control, A1. ARA forralization, and clarification of the authority delegated to the Health Physics Organization. These items are set forth in Appendix A, "Significant Appaisal Findings." Your past performance i
ceasemars Pe er coupesy fJtiN 13 $80 ta. personal esposere and radiological eff1===r sentrols has been accept-able but we believe that the identified wanha==ee require astrostion to enable you to perform equally won in futurs moraal and effeerasi eitaatises... Year presamt health physica program is considered adequate to empport senti==ad operaties while askieving acceptable eerrective estion for the identified weaknesses.
En recosaias that sa supliait regulatory requirement per*=4=4=s to each significant -b===
identified im Appendiz & may est carrently exis t.
Iowever, to detaruina ubether adequeta pratacties viu be provided for the health and safety of workers and the public, yee are requested to submit a writtaa statement withis tematy (20) days of your receipt of this latter, describing your carrective acties for each significant wesk-ames identified in M
'iw A, includings (1) stape skich have been taken; (2) steps dirk win be takaa; and (3) a sahadale for asuplation of action.
This request is mods purescat to Secties 30.34(f) of Part 30. Title 10, Cada of Federal Eagulatises.
Daring this orpraisal, it see aloe foemd that eartain of your estivities do not appear to have been emeducted is fun esepliance with BC requirements, as set forth in the Estice of Violaties==etamed as Appendix 3.
The items of menegliance in Appendix B have been categorised ists the Imrela of severity as described ta ser critaria for hforcement Action dated December 13, 1974. Sectica 2.201 of Part 2, Title 10, code of Federal Regulations, requires you ta submit ta this office, within toesty (20) days of your receipt of this metica, a written stata===t er emplanaties in reply, in-
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sludingt (1) eerrective stape skich have been takaa and the results acaisved; (2) eerrective etape which win be takes to avoid further itme of ase-compliance; and (3) the date when inn asupliance win be etteved.
You should be sears that the anzt stap la the B C affort to otraagthen benith physics programs at nuclear power plaats sin be a requirement by the Office of Emelaar Raaster Regulatism (IRA) that sech licenses develop, sabuit ta the ERC for approval, and implement a andf aties Protecties Plan.
Each limassee vin be espected to ime1=da in the Radiatian Protecties plas sufficient measures to provide lasting eerrective action for siseificant
- 1r=== - identified during the special appraisal of the current health physica program. Ontdance for the devalepeemt of this plan win incor-porata pertiment ff=df npa free au special appraisala and win be issued by ERA is the fall of this year.
In accordance with 3ection 2.790 of the ERC's *Enles of Practice," part 2, Title 10, Code of Federal Bagulattees, a espy of this letter and the en-eleesras will be placed in the ERC's Public Document Room. If this antarial 1
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contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. 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 epecificity the items which will be considered by the Commission as listed in Subparagraph (B)(4) of Section 2.790. The information sought 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 le.tter and the enclosures will be placed in the Public Docu-ment Room.
k'e will gladly discuss any questions you have concerning this inspection.
Sincerely, James G. Keppler Director
Enclosures:
1.
Appendix A Significant Appraisal Findings 2.
Appendix B, Notice of Violation 3.
IE Inspection Report No. 50-155/80-04 cc w/encis:
Mr. D. P. Hoffman, Nuclear Licensing Adninistrator Mr. C. J. Hartman, Plant Superintendent Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission m.=.,
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Appendix A f
SIGNIFICANT APPRAISAL FINDINGS Consuaers Power Company License No. DPR-6 Based on the Health Physics 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 prot..ction 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 ppropriate radiological precautions. The individuals provid-ing this coverage must not be assigned other duties under the emer-gency organization which detract from their primary responsibility for radiation protection coverage.
(Section 3.a) 3.
The N; ARA program requires significant improvement, especially in the areas of program formalization and Chemistry and Radiation Protection staff authority.
(Sections 3.c and 10) 4.
The training program requires significant improvement, especially in the areas of Chemistry and 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) 6.
Personal contamination soaitoring 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 6.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) 1 i
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a Appendix A.
8.
Although not indicative of brv.J problem areas, significant weak-nesses requiring corrective actions were identified in the follow-ing areas'i
-,High radiation area access controls.
(Section 8.d) i Supply of stard-off (extendible probe), high range survey instruments j
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) p, e m
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