ML20197G305
| ML20197G305 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/22/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| 50-155-97-11, EA-97-237, NUDOCS 9712300424 | |
| Download: ML20197G305 (2) | |
See also: IR 05000155/1997011
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December _22 1997
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EA 97 237
Mr. K. P. Powers
Plant General Manager
Big Rock Point Nuclear Plant
Consumers Energy Company
10269 US 31 North
- Charlevoix, MI 49720-
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT d-155/97011(DRS))
. Dear Mr. Powera:
This will acknowledge receipt of your letter dated December 9,1997, in response to our
letter dated November 19,1997, transmitting a Notice of Violation associated with the
falsifications of various survey records at Big Rock Point. We have reviewed your corrective
actions and hase no further questions at this time. These corrective actions will be examined
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during future inspections.
Sincerely,
Original Signed by John M. Jacobson (for)
John A. Grobe, Director
Division of Reactor Safety
Docket No. 50-155
lJcense No. DPR-6
Enclosure:
Lir dtd 12/9/97 K. P. Powers .
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Consumers Energy to US NRC
cc w/o encl:
R. A. Fenech, Senior Vice President,
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Nuclear, Fossil, and Hydro Operations
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Richard Whale, Michigan Public
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Service Commission
cc w/ encl:
- Michigan Department of Public Health
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- Department of Attorney General (MI)
- DOCUMENT _NAME: G:DRS/BRP12227 DRS
- To receive a copy of this document, Indlute in the box; 'C' = Copy w/o att/smcl *E" = Cop" w/att/end *N' = No cogr _
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December 22, 1997
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- December 9. 1997
Nuclear Regulatory Commission
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Document Control Desk
20555-0001
DOCKET 50 155
LICENSE D'PR 6
BIG ROCK POINT PLANT
-REPLY TO A NOTICE OF
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VIOLATION
NRC' INSPECTION REPORT 97014.
Follwing an NRC investigation of the falsification of various radiation.
survey records at Big Rock Point.-two violations of NRC requirements were
identifled and forwarded by letter dated November 19, 1997.
The first violation concerns radiation surveys required by station procedures
that were not completed as indicated in station-records on three separate
occasions. The second violation addresses the fact that plant records of these
surveys contained false information and were not accurate in all material
respects, which is not in accordance with 10 CFR 50.9. Consumers Energy
concurs with thellRC in that the actual safety significance of the incident
was low because the areas to be surveyed were not high radiation areas or
airborne radioactivity. areas, and subsecuent surveys did not indicate any
significant changes in radiological concitions.
Consumers Energy Company agrees with the violations as stated.
' Pursuant to the direction provided in-the report, find attached a Reply to the-
Notice of Violation. The corrective actions taken and proposed are intended to
address the concerns expressed by the NRC Inspectors, and to prevent
-recurrence of similar incidents.
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Kenneth P Powers
Site Director and Decommissioning General Manager-
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CC: Adminit,trator, Region III. USNRC'
NRC Resident Inspector - Big Rock Point
NRRProjectManager-OWFN,USNRC
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CONSUMERS ENERGY COMPANf
Big Rock Point Plant
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Docket 50-155 License DPR-06
Response to NOTICE OF VIOLATION - dated November 19, 1997.
At the request of the Commission and pursuant to the Atomic Energy Act of 1954
and the Energy Reorganization Act of 1974, as amended, and the Commission's
Rules and Regulations thereunder, Consumers Energy Company submits our
response to NRC letter dated November 19. 1997, entitled, " Notice of Violation
(NRC Inspection Report No. 50-155/97014",
Consumers Energy Comp ny's response
is dated December 9, 1997.
CONSUMERS ENERGY COMPANY
- To the best of my knowledge, information and belief, the contents of this
submittal are truthful and complete.
By
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Kenneth P Powers
Site Director and Decommissioning General Manager
Sworn and subscribed to before me this 1 th day of 1997
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Charl voix Co/ielms. Notary Public
unty, Michigan
My commission expires August 29, 1999.
(SEAL)
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ATTACHMENT
CONSUMERS ENERGY COMPANY
BIG ROCK POINT PLANT
DOCKET 50 155
REPLY TO A NOTICE OF VIOLATION
INSPECTION REPORT 97014
Submitted December 9, 1997
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REPLY TO A NOTICE OF-VIOLATION - NRC INSPECTION REPORT 97014
During an NRC investigation conducted fran Decenber 16. 1996. tbrough Apri1
10. 1997, wIth continuing NRC review through Novmber 7.1997. two vfolations
of NRC requirements were identified. In accordance with the " General Statement
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of Policy and Procedure for NRC Enforcement Actions. " NUREG-1600. the
violations are listed below:
Violation 97014-01
Technical Specification 6.11 (Radfation Protection Programs} requires
that procedures for personnel radiation protection shall be prepared
consistent with the requirements of 10 CFR Part 20 and shall be
approved. maintained, and adhered to for all operations involving
personnel rad!Mion exposure.
Station procedure RP-29. " Radiological Surveys" contains requirements
to monitor radiological conditions (routine and nonroutine) and provide
a routine check of sone of the equipment used to monitor-these
conditions.
Contrary to the above, certain radiation surveys required by station
procedure RP-29 were not cmpleted. Specifica11y. on July 21.1996, a
-required daily air sanple on the 585' level of the Reactor Containment
Building was not coapleted; on July 20 and 21.1996, a required daily
radiation survey for the exterior cable penetration room was not
conducted: the monthly survey required for the Radwaste Building was not
coupleted in Septenber 1996: and a required air sample was not coupleted
in the Radwaste Building on Septenber 15, 1996.
ThIs is a Severity Level IV Vlolation (Supplement IV).
Violalion 97014-02
10 CFR 20.1501 requires. in part, that each licensee shall make or cause to be
made surveys that may be necessary for the licensee to comply with the
regulations in this part.
Pursuant to 10 CFR 20.2003, survey means an evaluation of the radiological
conditions and potential hazards incident to the production, use. transfer,
release, disposal, or presence of radioactive material or other sources of
radiation.
10 CFR 20.1201(a)(1)(1) requires, with exceptions not applicable here that
the licensee control the occupational dose to individual adults to an annual
dose limit of 5 rems total effective dose equivalent.
10 CFR 20.2103 requires, in part, that each licensee maintain records showing
the results of surveys required by 10 CFR 20.1501 for 3 years after the record
is made.
10 CFR 50.9 requires. in part. that information required by the Ca7mi'ssion's
regulations to be maintcined by the licensee shall be cmplete and accurate in
all material respects.
Contrary to the above certain radiation survey records required to be
maintained by the Comission's regulations were not accurate in all material
respects. Specifically. these records indicated results for surveys which had
never been per formed. These surveys consisted of the following: a July 21.
1996. daily air sanple on the 585 * 1evel of the Reactor Containment BuiIdiog:
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REPLY 10 A NOTICE OF VIOLATION - NRC INSPECTION REPORT 97014
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- July 20 and 21.1996. daily radiation surveys of the exterior cable
'penetralion room; a Septeber 15. 1996. air sample of the Radwaste buiIding;
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and a Septemner.1996. nonth1y survey of the Radwaste Bui1 ding.
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Consumers Energy Contany agrees with the violations as stated.
-1. Reason for the violations.
Big Rock Point management could not determine any extenuating circumstances or
valid answers for tnis individual's falsification of less than 1% of his
assigned work in the preceding year, other than his inappropriate conduct and
standards.
Discussion
The Big Rock Point management staff initiated a special review of Radiation
Protection work activities in response to an em)loyee concern in October.
1996. The special three week review confirmed tiat persor.nel were conducting
. activities in compliance with plant piocedures, policies, and regulatory
' requirements with one issue being identified. Management pursued this issue
relevant to survey time inconsistencies with one individual. This
investigation concluded that the individual had not >erformed some surveys,
and that he willfully falsified records indicating t1at these surveys ha.. been
performed.
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II. The corrective steos that have been taken and the results achieved.
lhe areas were resurveyed. The individual's access to the site was terminated
and the com)any accepted the employee's resignation soon after. Radiation
Protection )epartment meetings were conducted to discuss the specifics of the
event, the status of the individual involved, and to re-enforce requirements
and management expectations for conduct of work at the site. Furthermore, the
Radiation Protection Department has added a Radiation Protection Self
Assessment position staffed by a highly cualified individual from outside
Consumers Energy Compar.y. This person adcs a level of continual-focused
management self assessment by reviewing day-to-day activities within the
organization. The Nuclear Performance Assessment Department, an independent
quality assessment review group, has also hired a highly qualified individual
from ouside the company with'over 17 years of health physics and related
experience to strengthen their oversight capabilities in this important area.
These actions have been appropriately received by the plant staff and routine
management checks over the last year collaborate that there are no other known
survey inconsistencies to-date.
III The corrective steos that will be taken to avoid recurrence,
As issued by the NRC and nuclear industry experience groups, notices that
provide information involving willful misconduct are routinely communicated to
the radiation protection staff to re-enforce management's zero tolerance for
willful acts contrary to regulatory requirements. This ongoing action coupled
with the corrective actions already taken are expected to prevent the
recurrence of this issue.
IV. The date when the facility Will be in ru11 como11ance.
The facility is currently in full compliance.
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