ML20203D128

Responds to NRC Re Violations Noted in Insp Rept 50-155/97-14.Corrective Actions:Resurveyed Areas,Accepted Involved Employee'S Resignation,Conducted Radiation Protection Dept Meetings & re-enforced Mgt Expectations

ML20203D128
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/09/1997
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-155-97-17, NUDOCS 9712160118
Download: ML20203D128 (5)

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. M A ChG Elegy Gwtaw B g &O Pwn! Nuclear Paot Kennen P Peevers 10269 US 31 North Plant Ceeral AI,maaer CMnevoa. Af 49720 December 9, 1997 Nuclear Regulatory Commission Document Control Desk Washington. DC 20555-0001 DOCKET 50 155 LICENSE DPR 6 BIG ROCK POINT PLANT REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 97014.

Following an NRC investigation of the falsification of various radiation survey records at Big Rock Point, two violations of NRC requirements were

'; identified 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 accordarv e with 10 CFR 50.9. Consumers Energy concurs with the NRC in that the actual safety significance of the incident was low because the areas to be a veyed were not high radiation areas or

- airborne radioactivity areas, av subsecuent surveys did not indicate any significant changes in radiological concitions.

Consumers Energy Company agrees with the violations as stated.

Pursuant to the directis' pre .ded in the report, find attached a Reply to the Notice of Violation. The er ect ve actions taken and proposed are intended to address the concerns expressed by the NRC Inspectors, and to prevent recurrence of similar incidents.

Kenneth ? Powers #

Site Director and Decomm:isioning General Manager i

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CC: Administrator, Region III. USNRC NRC Resident Inspector - Big Rock Point NRR Project Manager - OWFN. USNRC ATTACHMENT 9712160118 971209 PDR ADOCK 05000155 .

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CONSUMERS ENERGY COMPANY Big Rock Point Plant 4

. 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 tnergy Act of 1954 and the Energy Reorganization Act of 1974. as amended. and tne Co' mission's Rules and Regulations thereunder. Consumers Energy Company rubmit: our response to NRC letter dated November 19. 1997, entitled. "hy. ice of Violation (NRC Inspection Report No. 50-155/97014" Consumers Energy C>mpany'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 /

Kenn'eth P Powers Site Director and Decommissioning General Manager Sworn and subscribed to before me this 1 th day of 1997

_b;.a.; 4, . C-lb bmk Arm i # i.yrin/lelms. Notary Public

//'Chargc,axCounty, Michigan

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v/ My commission expires August 29, 1999.

(SEAL)

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ATTACHMENT CONSUMERS ENERGY COMPANY BIG ROCK PGINT PLANT DOCKET 50 155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 97014 Submitted December 9. 1997 2 Pages

D REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 97014 During an NRC investigation conducted from December 16. 1996. through April

10. 1997. with continuing NRC review through November 7.1997, two violations of'NRC requirements were identified. In accordance with the " General Statement

. of Policy and Procedure for NRC Enforcement Actions. " NUREG-1600, the violations are listed below:

Vlolation 97014-01 Technical Specification 6.11 (Radiation 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 radiation exposure.

Station procedure RP-29. " Radiological Surveys". contains requirements to monitor radiological conditions (routine and nonroutine) and provide a routine check of some of the equipment used to monitor these conditions.

Contrary to the above, certain radiatfor surveys required by station procedure RP-29 were not completed. Specifica11y. on July 21. 1996 a required daily air sample on the 585

• 1evel of the Recctor Containment BuiIding was not completed: 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 completed in September 1996; and a required air sample was not completed in the Radwaste Building on September 15. 1>36.

This is a Severity Level IV violation (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 Comission's regulations to be maintained by the licensee shall be complete and accurate in all matertal 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. Specifica11y. these records indicated results for surveys which had

' never been performed. These surveys consisted of the following: a Jury 21.

1996. daily air sample on the 585' level of the Reactor Containment Building: '

O REPLY TO'A NOTICE OF VIOLATION - NRC INSPECTION REPORT 97014-July 20 and 21,1996, daily radiation surveys of the exterior cable penetrat. ion room: a Septerrber 15. 1996, air sanple of the Radwaste building:

and a September.1996. monthly survey of the Radwaste Building.

Consumers Energy Company agrees with the violations as stated. ,

I. Reason for the violations.

Big Rock Point management could not determine any extenuating circumstances or valid answers for this 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 t1at personnel were conducting activities in compliance with plant procedures, 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 aerformed some surveys, and that he willfully falsified recoras indicating tlat these surveys had been performed.

II. The corrective stens that have been taken and the results achieved.

The 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 Jepartment 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 Company. 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 4

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 exoerience 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 full comoliance.

The facility is currently in full compliance.

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