ML20148L330
| ML20148L330 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/13/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20148L328 | List: |
| References | |
| NUDOCS 8012090474 | |
| Download: ML20148L330 (1) | |
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Appendix B NOTICE OF VIOLATION j
Consumers Power Company License No. DPP-6 Based on the Health Physics Appraisal conducted March 34 4, 1980, it appears that certain of your activities were in noncompliance with FRC requirements, as noted below.
Items 1 and 2 are infractions.
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 for-warded in a letter from Ziemann (NRC) to Bixel (CPCo) dated March 15, 1977.
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Contrary to the above, offsbif t radiation protection coverage is routinely provided by the shift supervisors, who typically are not qualified to conduct special and routine contamination and airborne radioactivity surveys and evaluating the results of such surveys.
2.
10 CFR 20.203(c)(2) requires that high radiation areas be equipped with control devices, which reduce radiation levels or provide aud-1 ible warning of the levels, or be maintained locked.
l Contrary to the above, high radiation areas existed fn the condensate j
demineralizer room and in the vicinity of the turbine moisture separa-tor at the time of this appraisal 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 i
short periods due to activity buildup on the filters. Although not a high radiation area during this appraisal, the area is net equipped with a control device or locked when high radiation levels exist.
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a..~.. s.c w.oa. u.c a.o.a.ow.. A,.. coa. su na os so July 1$, 1980 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Cor:nission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - RESPONSE TO EEA TH PHYSICS APPRAISAL By NRC letter dated June 13, 1980, consumers Power Company received the results of a Health Physics Appraisal, Inspection Report No 80-Oh, performed on March 3-lb, 1980. Consu=ers Power Company's respense to two (2) violations and eight (8) find-ings was requested.
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 Pcver Company's response to the violations and find-ings.
David ? Eoffman (Signed)
David P Hofftan Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector, Big Rock Point 1gggu W JUL 21 f.an
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, CONSUMERS POWER COMPANY BIG ROCK POINT PLANT RESPONSE TO HEALTH PHYSICS APPRAISAL DATED JUNI 13, 1980 The following is our response to the " Notice of Violation" contained as Appendix 3 and.the "Significant Appraisal Findings" contained as Appendix A in your letter of June 13, 1980, transmitting the results of your health
, h[ sics appraisal of the Big Rock Point Nuclear Plant.
p Appendix B - Notice of Vio12tiens 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 reacter.
- The criteria required to be satisfied by individuals qualified in radietion protection procedures were forwarded in a letter from Ziemann (!!RC) to hixel (CFCo) dated March 15, 1977 Contrary to the above, off-shift radiation protection coverage is routinely provided by the shift supervisors, who typically are not qualified to conduct special and routine contamination and airborne radioactivity surveys and evaluating the results of such surveys.
Restense Consumers Pover 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 centends the Technical Specificatien is satisfied by the qualifications maintained by the shift supervi".r (SS). The Big Rock Point Plant Administrative Procedures document the responsibilities of the SS vith respect to radiation protection coverage.
The previously accepted practice satisfying this Technical Specification by l
relying on both the on-shift supervisor who is trained in health physics procedures through the RO/SRO training programs and consequent licensing by the US NRC and the en-shift operators who are trained in health physics procedures i
through the RO training program and also licensed by the US NRC will be continued.
In addition, all on-shift operators, the shift supervisor and the shift technical advisor vill continue to be trained at the plant for RWP exempt status.
However, in view of our concer.1 for maintaining a current and high quality i
radiation protection program at Sig Nock Point, Consumers Power Company vill proceed with the establishment of a new supervisor; training position at the plant. The individual filling this position vill be responsible for upgraded radiation protection trsining of the plant staff. The traininr program will be fully implemented 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 liemann's letter of March 15, 1977, to Consumers Pover Conpany. Under this program additional deta13ed training in radiological evaluations, particularly for offsite dose consequences under abnormal conditions, vill be provided to the shift technical advisors. Also, a careful screening of the need for RWP-exempt status vill be undertaken to minimi:e its use to individuals truly in need of an RWP-exemption.
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2 CPCo Big Rock Point Pitnt Response to Haalth Physics Appraisal
. datsd Juns 13, 1980 During routine operation of the plant, the non-day shift cc pler.ent consists of only six e=ployees. Because of the small nu=ter of people, verk force radiation protection control during normal operations or durinE the initial stages of an emergency by the shift supervisor is a relatively easily =anaged task. However, when the work in radiologically controlled areas involves non-RWP-exempt personnel such as maintenance personnel during off-snift hours, it vill 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 radioloE cally controlled area that are not i
part of the normal shift cocplement, radiation protectica technician coveraEe vill be provided. We believe with these additional steps that the shift supervisor vill remain fully qualified in radiation protection procedures to satisfy Technical Specification 10.6.2.2(d) to assure competent radiation protection coverage while,s fuel is in the reactor.
Violation Item #2 10 CPR 20.203(c)(2) requires that high radiation arets 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 desinera-li:er room and in the vicinity of the turbine moisture separator at the tire of this appraisal but the areas were not locked or equipped with control derices.
An additional area, surrounding the spent fuel pool sock filter tank, beccces 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.
Pescense Const=ers Power Co:pany ackncviedges the absen:e of locks for the high radiaticn areas in the condensate de=inerali:er room an(. in the vicinity of the turbine l
coisture separctor.
1 1
To correct this infraction, Consumers Power Ccmpany is co==itting to the fellowing:
l 1.
The turbine area is now a locked and a.sr=ed high radiation area.
The entrance to the condensate de=ineral. er is presently chain locked and 2.
vill be 'provided with a locked door by Ja.uary 1,1981.
3.
The fuel pool filter area is presently cha.n locked.
L.
In order to assure that the area ic=ediatel: above the fuel pool filter does not become a high radiation area, procedural controls vill be instituted immediately to change the filter. elements before this area becomes a high rad'.ation zone. Such procedural controls may also be acceptable for the fuel pool filter area.
If the fuel pool filter area, even with these procedural controls, becomes 5
a high radiation area,on a periodic basis, it vill be provided with a locked door.
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CPCo Big Rock Point Plcnt Response to Haalth Physics Appraisal 3
4ated June 13, 1980 Actandix A - Significant Appraisal Findings Alth ) ugh these "Significant Appraisal Findings" are not in violation of Federal Regu'. ations,. Consumers Power Company vill proceed with the following to main-tain and improve the radiation protection program at Big Rock Point.
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pindina Ts chnician and professional staffing within the Chemistry and Radiation
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Pr ttection Department is not sufficient to allow adequate training of personnel, to provide reasonable assurance that persennel loss vill net adv trsely affect essential Chemistry and Radiation Protection Department tunt tions, and to allow adequate performance of assigned responsibilities unde.. routine and anticipated nonroutine conditions (Section 3.b).
Respouse Consumtra Power Company is proceeding with the establish =ent of an addi-tional professional position most likely within the Chemistry and Radiation Protection Department. This individual vill be responsible for improving and maint aining the training, RWP-exempt and ALARA programs.
Consumers ?over Jompb y is also actively seeking two Radiation Protection Technicians to fill a new authorized complement of eight (B) people. This vill allow tLe adequate performance of assigned responsibilities under routine and articipated nonroutine conditions.
The additional professional position is expected to be filled by January 1, 1981, depending on the availability and qualifications of applicants.
2.
Findina Off-shift radiatien protection coverage requires upgrading to assure that necessary measuremetts can be made and actions taken in accident or 'other anpmalots situations to evaluate radiological hazards and effect appropri-ate radiological precrations. The individuals providing this coverage must not be assigned other duties under the emergency organization which detract from their primary responsibility for radiatien protection coveraEe (Section 3.a).
Resonnse As noted in Constners Power Company response to Notice of Violatien Ita:
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- 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 RVP-exempt personnel. Furthermore, the' licensee shares the audit team's cen-cern with regard to avsilability of training time, recent technician turn-over, workloads and availability of qualified people available for fillinE l
the currently authori:ed but unfilled technician positions. Off-shift coverage vould vorsen the situation with respect to these other concerns.
Purthermore, it would limit severely the licensee's ability to provide adequate maintenance support (RWP processing, direct coverage and job evaluations, etc), during the normal (daytime) maintenance shift.
However, plant management currently is reviewing a nunber of alternatives l
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)y dPCO Big R:ck Print Plant Rssponse to Haalth Physics Appraisal L
dated June 13, 1980 for maintaining responsiveness to increased regulatory requirements in all phases of plant operation.
-J 3.
Finding The ALARA progam requires significant improvement, expecially in the areas of program femalization and Chemistry and Radiation Protection staff authority (Sections 3.e and 10).
Resoonse See Consu=ers Power Company response to Finding #1 of Appendix A above.
In addition corporate management agrees with the desirability of additional formalization and company-vide uniformity 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 1960. This policy will also address the authority of the Radiation Protection Department including the ability to enforce radiation protection procedures and stopping vork on jobs believed to be radiologically hazardous.
L.
Finding The training program requires significant improvement, especially in the areas of Chemistry and Radiatier. Protection Technician training and RWP-exe=pt training (Sections k.a and b, and 12.a).
Restense Desirability for improvement is acknowledged. See Consu=ers Pover Company response to Finding #1 above.
5.
Finding The RVP-exempt program, in its present form, has significant wear.nesses in training of personnel and in basic for=at (Sections h.b and 8.b).
l Resronse This program is expected to be strengthened by establishment of an additional prefessional position. See Consumers Power Company respense j
to Finding #1 and Violation #1, abe l
6.
Finding Personal contamination monitoring practices require significant improve-l
. ment in the areas of equipment sensitivities, formal procedures describ-l I
ing equipment calibrations and alarm setpoints, and enforcement of pro-l cedures for use of personal conta=ination equipment (Sections 8.c and 9.c l
and d).
I Reseense The improved training program as a result of the additional professional assistance vill promote a better understanding of radiation protection procedures and mitigate the need for additional enforcement action.
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to H alth Physics Appreissi 5
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. CPCo Big Rock Point Plant R3sponss
. 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.
l Proper frisker use vill also be emphasized in the i= proved training progrum to maintain radiation exposure ALARA along with an evaluation of frisker sensitivity and relocation to lover noise and radiation background areas.
Formal procedures vill be developed describing equipment calibratio'ns and alarm setpoints where necessary.
7 Findina Airborne effluent controls require improvements in noble gas quantificatien methods, laboratory ventilation release determinations, and EI?A filter changeout and testing criteria (Section 11.b).
Response
A hi6a 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 fcr this monitor to quantify noble gas releases.
By January 1,1981, a study and analysis will be completed on stack gas sam-ples to determine that the present stack gas monitor quantifies noble gas release rates appropriate and that the off-gas is the overwhelming contritu-A germanium detector coupled to a multichannel analy-tion to total release.
recuirements of !!URIG-sis system is being designed to satisfy the long-ter 0578. This system vill be operational according to the NRC-defined schedule.
Monthly surveillance by contamination surve/ en the laboratory exhaust fan duct vill be implemented by September 1,1980..
HI?A filters vill be scheduled for changeout and/or sa=pling to determine if changeout is neces-sary on a routine basis. This scheduling is expected to occur by January 1, 1981.
8.
FindEne Although not indicative of broad problem areas, significant weaknesses requiring corrective actions were identified in the following areas:
High radiation area access control (Section 8.d)
A.
Supply of stand-off (exten' ding probe), high range survey instru=ents and survey instrument operability checks before use (Section 9 2)
B.
Procedure coverage and adherence (Section 6)
C.
Temporary storage of low-level radioactive trash (Section 11.c)
D.
Reseense Consumers Pover Company is currently evaluating these areas for possible The following provides our objectives in relation to the improvement.
above items:
'igh radiation area access control is addressed by the response to d
A.
Violation Item #2 above.
Evaluation and recommendation for purchase of additional radiation protection instruments will be completed by September 1,1980.
B.
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CPCo Big Dock Point Plant Response to Health Physics Appraisal 6
dated June 13, 1980
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C.
The training program vill emphasize radiation protection procedure adherence in accordance with the responses to Violation Item #1 and applicable findings.
D.
Temporary storage of low-level radioactive trash vill be improved by establishment of procedural controls in the form of bag limits or container storage. These contrels i
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vill be established by September 1, 1980.
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- 3. DeWitt Vice President Nucisar Operations 212 West Michigan Avenue Jsekson, MI 49201 Gentlement Thank you for your letter dated July 18, 1980, inforning as of steps you have taken to correct the appraisal findings and the noncompliances j
identified in our latter dated June 13, 1980.
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'a general your proposed corrective actions for the Significant Appraisal Ju ding items appear to represent a positive approach to resolving these problems and thereby strengthening your everall health physics program.
j Us will evaluate your progress in thoge areas ing subsequent inspec-tions. Tour response to %ignificant W isisal ing No. 2 off-shift J
radiation prot. action staffing will be forwarded to ERC headquarters for i
resolution.
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Your proposed corrective actions for the noncompliances will also be j
====i=ad during a future inspection. Although you have proposed cor-rective setion for moneoupliance Itan 3o.1, we omderstand that you wish to contest this noncompliance as stated in your latter of August 11, 1980.
This matter also has been referred ta sur headquarters for resolution.
Tour cooperation with as is appreciated.
Simeerely,
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i James C. Esppler j
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est Mr. D. P Boffman, Baclear i
Licensing u=4a4=crator Mr. C. J. Bartman, Plant j
Superiatandent oc w/itr dtd 7/18/80:
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.SEP 2 41999 Docket No. 50-T55 Consumers Power Company ATTN : Mr. - R. B. DeWitt Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
This refers to your letters dated July 18 and August 11, 1980, and our letters. dated June 13 and August 26, 1980, regarding the Health Physics Appraisal conducted by this office in March 1980..As stated in our August 26, 1980 letter, your positions regarding Fignificant' Appraisal Finding No. 2 and Noncompliance Ites No. I were forwarded to our Head-quarters for resolution. The responses from our Headquarte,s are sum-marized below.
Regarding Significant Appraisal Finding No. 2, our Headquarters concurred with the Appraisal findings but noted the lack of specific regulatory requirements for dedicated radiation protection personnel on off-shifts.
Our position remains, as stated in our June 13, 1980 letter, that off-shift radiation protection coverage should be upgraded to ensure effective accident response. Note also that NRR is currently evaluating shift staffing requirements in conjunction with their review of licensee emergency plans. No further action is planned by this office at this time.
Regarding Noncompliance Ites No. 1, our He&dquarters agreed that the noncompliance' citation was valid. The following rationale was provided:
"The NRC provides information for the purpose of clarifying the specific meaning and intent of regulatory requirements by numerous means; some examples are Statements of Consideraf. ion, Regulatory Guides, NUREG documents, Bulletins, Circulars, B.anch Technical Positions, and Generic Letters. These documents do not establish regulatory requirements, but simply clarify the meaning and intent of esistias requirements or denote acceptable methods of imple-menting the regulatory' requirements. Consumers Power company acknowledges receipt of the clarifying information provided in the i
letter from Ziemann to lixel dated March 15, 1977 and did act pro-pose or receive approval for implementing an alternative means of complying with the subject technical specification."
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r 2-SEP 2 41980 Consumers Power Company Inasmuch as your proposed corrective action for this noncompliance appears acceptable, no,further action is planned by this office at this time.
Your cooperation with us is appreciated.
.n Sincerely, 1
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f7JamesG.Kephfer Director ec:.-Mr. D. P. Hoffman, Nuclear Licensing Administrator Mr. C. J. Hartman, Plant Superintendent ec w/1trs dtd 7/18/80 and 8/11/80:
Central Tiles Reproduction Unit NRC 20b AEOD Resident InJpector, RIII PDR Local PDR KSIC TIC Ronald Callen, Michigan Public Service Commission w-r-
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