ML20217J321

Discusses Insp Rept 50-155/97-05 on 970303-0428 & Forwards Notice of Violation.Violation Occurred During 970202 Tour of Steam Drum & Piping Areas in Radiologically Controlled Area & Failure to Respond to Electronic Dosimetry Alarm

ML20217J321
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/12/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Flowers R AFFILIATION NOT ASSIGNED
Shared Package
ML20217J323	List: ML20217J321 ML20217J339
References
50-155-97-05, 50-155-97-5, IA-97-063, IA-97-63, NUDOCS 9710210038
Download: ML20217J321 (3)

See also: IR 05000155/1997005

Text

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Mr. Raymond J. Flowers

(HOME ADDRESS DELETED

UNDER 10 CFR 2.790)

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50155/97005(DRS))

Dear Mr. Flowers:

This refers to the inspection conducted on March 3,1997, through April 28,1997, at the

Big Rock Point Nuclear Plant, a Consumers Power Company facility located in Charlevoix,

Michigan. This inspection reviewed the circumstances surrounding the February 2,1997,

tour of the steam drum and piping areas in the radiologically controlled area when you, a

licensed shift supervisor, failed to appropriately respond to an electronic dosimetry alarm.

A copy of the inspection report is enclosed. Enforcement actions are currently being

I

considered against Consumers Power Company for this event.

Based on the information developed during the inspection, the NRC has determined that a

violation of NRC requirements occurred. The violation is cited in the enclosed Notice of

Violation (Notice) and the circumstances surrounding it are described in detail in the

subject inspection report (enclosed). On February 2,1997, while accompanied by a

radiation protection technician, you performed a tour of the steam drum and piping areas

(high radiation areas) while the plant was operating at approximately 8 megawatts electric.

During this tour, the electronic dosimeters worn by the radiation protection technician and

you alarmed. When the alarms were received, the radiation protection technician indicated

that you had to leave the area per procedure. While you were fully aware of this

procedural requirement, you decided that personnel doses would remain as low as

reasonably achievable (ALARA)if you completed the tour at this time, and that this ALARA

consideration outweighed the requirement to leave the area. After completing the tour,

you exited the area, reported receiving the dosimetry alarms, and wrote a condition report

describing the event. The f ailure to exit the high radiation area after receiving electronic

dosimetry alarms during the tour is contrary to the requirements in Administrative

Procedure 5.8, "High Radiation Area Key and Access Control," Revision 10, Step 5.1.f.7

which requires such actions. The failure to adhere to this personnel radiation protection

procedure during operations involving personnel radiation exposure is a violation of

Technical Specification 6.11. Your actions also contributed, in part, to a Severity Level lil

Notice of Violation being issued to Consumers Power Company (enclosed). hv

This violation was caused by your casual attitude concerning radiation protection practices.

While keeping doses as low as reasonable achievable at all times is important, the ALARA

philosophy does not give individuals the authority to violate procedures. The failure to

follow procedures raises significant regulatory concerns. It is imperative that you, a \

radiation worker, appreciate the importance of complying with procedures and understand

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the conditions under which a procedure may not be required to be followed. While this

specific violation involved little risk to the public health and safety, the failure to adhere to

approved procedures in other situations could result in grave consequences.

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R. J. Flowers 2

You are reminded that you hold a license from the United States government that confers

upon you the special trust and confilence of the American people in the safe operation of

nuclear facilities and places you In the position where your performance is expected to be

above reproach. Your actions on February 2,1997, did not meet those standards.

Therefore, this violation has been categorized in accordance with the " General Statement

of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600

at Severity Level IV. However, similar violations in the future could result in more

significant enforcement actions.

The purpose of this letter is to make clear to you the consequences of your violation of

NRC requirements. You are required to respond to this letter and should follow the

instructions specified in the enclosed Notice of Violation (Notice) when preparing your

response. In your response, you should document the specific actions taken and any

additional actions you plan to prevent recurrence in order to ensurg your ability and

willingness to carry out the special trust and confidence placed in you as a licensed

operator of a nuclear power facility. After reviewing your response to this Notice,

including your proposed corrective actions, the NRC will determine whether further NRC

enforcement action is necessary to ensure compliance with NRC regulatory requirements,

in accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10. Code

I

of Federal Regulations, records or documents compiled for enforcement purposes are

placed in the NRC Public Document Room (PDR). A copy of this letter and the enclosed

Notico of Violation, and your response, with your address removed, will be placed in the

PDR after 45 days unless you provide sufficient basis to withdraw this violation.

Should you have any questions concerning this action, please contact Mr. Brent Clayton of

my staff. Mr. Clayton can be reached at either the address listed above or at (630) 829-

9666.

Sincerely,

, @ '

t . Bill Beach

Regional Administrator

Docket No. 55 30732

License No. SOP 311371

Enclosures:

1. Notice of Violation

2. Inspection Report 50-155/97005(DRS)

3. Notice of Violation issued

to Consumers Power Company

cc (WITH HOME ADDRESS DELETED UNDER 10 CFR 2.7901:

K. P. Powers, Plant General Manager

Consumers Energy Company

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R. J. Flowers 3-

DISTRIBUllON IWITH HOME ADDRESS DELETED UNDER 10 CFR 2.7901:

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LCallan, EDO

AThadani, DEDE

LChandler, OGC

JGoldberg, OGC

SCollins, NRR

RZimmerman, NRR ,

Enforcement Coordinators

Rl,Rilend RIV

Resident inspector, Big Rock Point

JHannon, NRR

LTran, NRR

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JGilliland, OPA

HBell, OlG

GCaputo, 01

Dross, AEOD

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