ML20217K552

Notice of Violation from Insp on 970303-0428.Violations Noted:Licensee Failed to Properly Evaluate Potential Radiological Hazards Associated W/Transfer of Highly Contaminated Filters

ML20217K552
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/12/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217K537	List: IR 05000155/1997005 ML20217K552
References
50-155-97-05, 50-155-97-5, EA-97-197, NUDOCS 9708150293
Download: ML20217K552 (3)

Text

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l NOTICE OF VIOLATION .

3 Consumers Energy Company Docket No. 50155 Big Rock Point Nuclear Plant License No. DPR 00 '

EA 97197 i

During an NRC Inspection conducted on March 3,1997 though April 28,1997, violations of NRC requirements were identified. In accordance with the

• General Statement of Policy d

and Procedure for NRC Enforcemen'. Actions," NUREG 1600, the violations are listed below:

A. 10 CFR 20.1501 regulres,in part, that the licensee make or cause to be made ,

surveys that may be necessary for the licences to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantitles of radioactive materials, and the potential radiological hazards that could be present.

Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive materlat or other sources of radiation.

10 CFR 20.1201(a)(1)(l), requires, in part, that the licensee shall control the occupational dose to individual adults to en annual total offective dose equivalent ,

limit of 5 rems (0.05 Sv).

10 CFR 20.1701 requires, in part, thr:t to the extem practicable, the use of process or other engineering controls (e.g., containment or ventilation) to control the concentrations of radioactive materialin air.

1. Contrary to the above, on February 2,1997, the licensee failed to properly evaluate the extont of radiation levels and the potential radiological hazards that could be present during a plant tour to ensure compilance with 10 CFR 20.1201(a)(1). Specifically, the pre job planning for the tour, which occurred during low power operation rather than at 0% power when usually conducted, did not address historical data, ALARA considerations, or the ,

radiological conditions in the area. (01013)

2. Contrary to the above, on February 24,1997, the licensee failed to properly evaluate the potertial radiological hazards associated with the transfer of the highly contamimd f!!ters. Specifically, the licensee failed to consider the impact of transwring the filters which had dried for a month, rather than a week or two as usual. This transfer was completed without establishing the '

appropriate ventilation pathway to control radioactive matenal in the air in accordance with 10 CFR 20.1701. (01023)

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h j Notice of Violation 2 B. Technical Specification 6.11 requires that procedures for personnel radiation ,

orotection 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.

Administrative Procedure 5.8, ?High Radiation Area Key and Access Control,"

e -(Revision 10), Step 5.1.f.7 required, in part, that a high radiation area shall be  ;

exited upon receipt of a personnel doclmetry alarm (eg, Electronic Dosimetry Entry >

j - Dose Level Alarm or Electronic Dosimetry Dose Rate Alarm).

Administrative Procedure 5.8,"High Radiation Area Key and Access Control,"

4 (Revision 10), Step 5.1.c required, in part, that high radiation areas having general ,

area radiation fields greater than one rem /hr shall not be entered without accompaniment by a second person. Both people should be high radiation area access quellfied, but if one is not, f.s or she shall be provided with dedicated radiation protection technician (RPT) coverage.

1. Contrary to the above, on February 2,1997, two licensee personnel did not exit a high radiation area after receiving electronic dosimetry alarms during a plant tour as required by Administrative Procedure 5.8, a procedure for personnel radiation protection. (01033) ,

2. Contrary to the above, on January 20,1997, a station engineer who wat not high radiation area access qualified entered the reactor water clean up l pump room (a controlled high radiation area) on two occasions without 4 dedicated RPT coverage as required by Administrative Procedure 5.8, a - -

procedure for personnel radiation protection. (01043)

C. 10 CFR 50.59, " Changes, tests and experiments," permits the licensee to make 4 i changes to the facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report without prior Commission approval provided the change does not involve a change in the >

Technical Specifications or an unreviewed safety question (USD). The licensee shall maintain records of changes in the facility and these records must include a written safety evaluation which provides the bases for the determination tnat the change does not involve a USO. -

10 CFR 50.9(a) requires, in part, that information provided to the NRC by a licensee or information required by regulation to be maintained by a licensee shall be complete and accurate in all material respects.

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s Notice of Violation 3

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Final Hazards Safety Report (FHSR), Section 11.3.2, states that air flow rates will remain sufficiant to minimize build-up of airborne contamination and that flows begin in radioactively clean areas and are directed to potentially more highly contaminated areas then exhausted to the stack.

Drawing number 0740040124, which is referenced in FHSR Section 11.3.2, Indicates that mir flows directly from the RWPA Into the exhaust plenum and out the plant stack. This drawing indicates that the damper on the radwaste processing area (RWPA) exhaust plenum was to be open.

Contrary to the above, on February 24,1997, the facility was not as described in the FHSR in that the alt flow and damper positions were was not as specified in FHSR drawing number 0740040124 and FHSR Section 11.3.2. The posillon of the RWPA exhaust plenum was closed which permitted air flow from the RWPA through the turbine building, into the pipe tunnel, and out the main stack. This air flow path resulted in a significant spread of contamination throughout the turbine building. A written safety evaluation was not performed to provide the bases for the determination that this change did not involve an unreviewed safety question. >

In addition, the updated FHSR was not complete and accurate in all material respects in that it did not reflect this change. '

This is a Severity Level lli probierit (Supplement I and Supplement IV).

t The NRC has concluded that Information regarding the reason for the violation, the corrective actions taken ond planned to correct the violation and prevent recurrence is already adequately addressed on the docket in inspection Report Nos. 50 155/97005(DRS), and your response to the inspection report dated June 18,1997.

However, you are required to respond to the provisions of 10 CFR 2.201 If the descriptiori in the docketed materials referenced above does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

Dated at Lisle, Illinois this 12th day of August 1997

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