05000155/LER-1987-009, Responds to NRC Re Violations Noted in Insp Rept 50-155/87-19.Events Cited in 870803 Encl LER 87-009.Issuance of Violation Contradicts NRC Policy to Encourage & Support Licensee Initiative to Identify & Correct Problems

Responds to NRC Re Violations Noted in Insp Rept 50-155/87-19.Events Cited in 870803 Encl LER 87-009.Issuance of Violation Contradicts NRC Policy to Encourage & Support Licensee Initiative to Identify & Correct Problems

ML20235P647
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	10/01/1987
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8710070336
Download: ML20235P647 (3)

LER-2087-009, Responds to NRC Re Violations Noted in Insp Rept 50-155/87-19.Events Cited in 870803 Encl LER 87-009.Issuance of Violation Contradicts NRC Policy to Encourage & Support Licensee Initiative to Identify & Correct Problems

Event date:
Report date:
1552087009R00 - NRC Website

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Director MM Nuclear Dcensing M M N5 M EKE '

General Offices: 1945 Woat Parnell Road, Jackson, MI 49201 e (517) 7881636

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DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - I RESPONSE TO INSPECTION REPORT 87019 Nuclear Regulatory Commission Inspection Report 87019 dated September 4, 1987

. transmitted one violation requiring a written response within 30 days.

Consumers Power' Company's response is provided herein.

Violation (50-155/87019-04)

'As a result of the inspection conducted on August 3-7, 1987, and in accordance with " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987),- the following violation was identified:

Big Rock Point Radiological Effluent Technical Specification 13.1.1 requires that the Radwaste Effluent monitor be in service at all times. However, the action statement for this specification (Table 13-1 Notation, Action 1) permits.cffluant releases via this pathway with the monitor inoperable, provided that prior to initiating a release:

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a. At least two independent samples are analyzed in accordance with Specification 13.1.2.2, and

b. The release rate cciculations and discharge line valving are verified by at least two technically qualified members of the Facility Staff.

Contrary to the above, on July 4 andL5, 1987, the licensee did not analyze two independent samples and did not verify the rate calculations and discharge line valving prior to initiating a planned release while the Radwaste Effluent Monitor valve was closed'and hence, inoperable.

Response

A detailed description and response to this event was provided in LER 87-009, dated August 3, 1987. Although Consumers Power Company acknowledged at the time of occurrence the event constituted operation outside Radiological 0C098/-0178-NLO4 yM F

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?T lReponse;to IR d7019' 10ctober 1 1987-F b Effluent Technical Specification requirements, the safety significance as u

-described in-the LER'was. minimal.. Per the guidance of 10CFR2, Appendix C, we p ;. >

,believe the violation should not have been cited. Issnance of a violation for F~" this event contradicts NRC policy to encourage and support licensee initiative iJ 'for-'self-identification and correction of problems. Consumers Power Company

, Management concludes'that the actions taken meet the tests outlined in 10CFR2, Appendix C, in that,the violation:

.l.- Was identified by the' licensee, F- 2. Fits in Severity Level'IV or V, 1

3. Was reported, per.10CFR50.73,

4. Was corrected and measures were included to prevent tecurrence within a a reasonable time period, and

[' L5. Was a first time' occurrence which could not have reasonably been expected to have been prevented by corrective action for a previous 4 ,

violation.

1"1 In this event the operating shift involved had made a conscious effort to verify and evaluate conditions'necessary for the release, however, judgement j,

errors resulted in the reportable condition. . Procedure improvements were determined to be the prudent action to prevent recurrence.

The three missed opportunities to correct the situation, as stated in the inspection report, occurred at the same time and, in a practical' sense, were only'one opportunity. In fact, one of the stated opportunities, proper interpretation of the monitor,uis what led to discovery of the condition and the resultant implementation of corrective action.

Attached is a copy of Licensee Event Report 87-009 forwarded to the NRC by letter dated August 3, 1987. This submittal describes both the corrective actions taken and the actions taken to prevent recurrence. As of the date of this response all corrective actions have been completed.

'$dk Ukef Renneth W Berry Director, Nuclear Licensing e

L .CC Administrator, Region III NRC NRC Resident Inspector - Big Rock Point Attachment t

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, num., = =_ . u., no l l l Big Rock Point Radiological Effluent Technical Specification 13.1.1 requires that the Radwaste Effluent Monitor be in service at all timas. The action statement for this specification however, per:aite affluent releases via this ,

pathway releases with the monitor inoperable, provided that prior to initiating a

a. At least two independent samples are. . analyzed in accordance with Specification 13.1.2.2, and

b. The release rate calculations and discharge line valving are vetified by at least two technically qualified members of the Facility Staff.

Contrary to the above, on July 5, 1987 at 0045 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />, it was discovered that a planned release was completed without the Radwaste Monitor valved into service.

Cause of the event is attributed to a personnel error. Subsequent reanalysis verified the release was within allowable Technical Specification limits.

Counseling and procedure changes have been completea to prevent recurrence.

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0f0 0l2 M "O g vore s .L. ans ==an-menwim Requirement, Big, Rock Point Radiological Effluent Teclinical Specif"fdstfon 13.1.1 requires that the Radwasta Effluent Monitor (IL) be in service at all times. The '

action statement for this specification however, permit.s effluent rele'ases via this pathway with" the monitor inoperable, provided; that prior to initiating a-releases

a. At least two independent samp1,gp are ap41ysed in accord &nce with Specification 13.1.2.2, and

b. The release rate calculations and discharge 1the valving are <erified by at les=c two technict.11y qualified. Maga et..tt,.a racility Staff.

Discussion of Event On July 4,1987 preparations were made to release #1 Dirty Wasta Receiver Tank (Batch #28-87) following completed processing. The tank was sampled and analyzed to determine release rate in accordance with Technical Specification 13.1.2.1.. At 1910 h0urs, the Shift Supervisor autherised release of batch 28-47'and instruct 6d plant operators to commence ths telease in accordance with plant procedures.

On July 5, 1987 at.0045 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />, following shift turnover, the control room operator noticed that the indications on the Rafiwaste Effluent Monitor 19oked abnormally low. An auxiliary operator was dispatched to check the valve lineup and reported that the Radwaste Effivent Mopitor discharge valve was closed resulting in no flow through the monitor. 'this absence of flow was the I

causs for the low monitor readings in the control room and resulted tu operation outside the requirements of Techaical 3 specification 13.1.1. Issediate actior.s were to terminate the release and contact the Chemistry Department who sampled the canal discharge tank and the remaining contents of the #1 Dirty Waste Receiver Tank. Valve lineup was also restored to normal.

Cause Root cause of the event is attributed to personnel errot as a result of poor judgement. An invaritigation of the occurracce identified that the operating ehift involved uad made a conscious effort to verify and evalcata che conditions necessary to retsass the waste, hcuever errors in judgement s resulted the reportable condstion. Review of the procedure used and discussions with the auxiliary operator cer.cluded that the conitor discharge valve position had been checked but the valve was closed tight and the " check" however did cat apply enough terque to the handwheel to recove ths gate from the seat. The auxiliary operator inadvertently fai_ led to check the sight glass for flow to the monitor following initiatiou cf the batch release. The control Ma sport.tcr upon initi.ation of the release did acknowledge an incr6ase in the monitor reading but failed to recognize that a much higher incr6ase should have occurred during the batch release.

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l Corrective Action Taken to Prevent Kecurrence

1. Promptly following the occurrence, employees involved received counseling and a disciplinary warning.regarding:their performance associated with this event.

2. An Operations Memo was issued to all Operations personnel describing the occurrence. This memo also requires that durir.g all batch teleases, an ,

l independent verification of all valve lineups be.. conducted and .verifi- J cation of proper flow and monitor response be documented in the log. 1 These instructions will remain in effect until procedure changes are d issued.

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3. Changes to batch release procedures have been initiated which now require operators to verify proper flow indication and affluent monitor response upon initiation of a batch release. The procedures also will require

, I immediate termination of the release should proper response not be evident.

4. Training programs will be enhanced to emphasize the important.s of verifying expected changes to system parameters and responsa when manipulating i system components or controls. The auxiliary operator training program will now include instruction on the proper methods to verify valve position du. ring lineups or system check sheets.  ;

Safety Assessment The radwasta effluent instrumentation is provided to monitor the releases of plant affluents to insure that alarms / trips will occur prior to exceeding the {

limits of 10CFR20. Although this function was out of service during the event, the potential for exceeding these limits did not exist since this was a { I preplanned release. Samples of the batch were analyzed in advance to insure compliance with Technical Specifications. Subsequent re-analyain following the event showed to'at the activity at the point of release never exceeded 0.26 l MPC, concluding no undue risk. j l

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