ML18057A634
| ML18057A634 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/11/1990 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9012170268 | |
| Download: ML18057A634 (6) | |
Text
consumers Power l'DWERINli MICHlliAN'S l'RDliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 December 11, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 2055&
DOCKET 50-255 -- LICENSE DPR PALISADES PLANT -
INFORMATION PROVIDED IN RESPONSE TO PROPOSED VIOLATIONS GB Slade General Manager -
The NRC's safety inspections90-019 and 90-028 identified activities that appeared to be in violation of NRC requirements.
These activities were also discussed at the enforcement conference for Palisades held on November 15, 1990 at the Region III offices. Although the inspection reports require no specific written response at this time, we feel its prudent to transmit our preliminary response to each proposed violation as a follow up to our discussions at the enforcement conference. Attached, we have provided a written response to each of the four proposed violations.
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Gerald B Slade Plant Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
-~012170268 901211 PDR ADOCK 05000255 G!
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A CM.S El\\/E'RGY COMPANY
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 INFORMATION PROVIDED IN RESPONSE TO PROPOSED VIOLATIONS December 11, 1990 4 Pages
NRC Apparent Violation No. 255/90028-01 Failure to provide instructions to personnel in the precautions and procedures used to minimize exposure to radioactive materials and radiation on the proper use of protective equipment is an apparent violation of 10 CFR 19.12.
The example given to support this violation was that individuals who were required to be given the practical factors portion of the General employee Training, were not given that portion of the training.
CPCo Response The radiation safety technicians involved in this apparent violation, received the training specified by Consumers Power Company to meet the requirements of 10 CFR 19.12, with one exception.
Each technician received and successfully passed General Employee Training, Radiation Safety Indoctrination and
- Radiological Protection Training.
The exception was Practical Factors Training in the donning and removal of an anti-contamination clothing (Anti-C's).
As each of the technicians had previous experience in donning and removing Anti-C's, and each was required to demonstrate the proper donning and removal of Anti-C's as part of the technician on-the-job training (OJT) program, it is considered that each technician was provided with sufficient instructions on the precautions and procedures used to minimize exposure and on the proper use of protective equipment.
Further, it is recognized that many other nuclear power facilities would normally "waive" these technicians from the practical factors training. Therefore, no violation of 10 CFR 19.12 occurred.
NRC Apparent Violation No. 255/90028-02 Failure to maintain accurate records of information which the NRC requires to be maintained is an apparent violation of 10 CFR 50.9(a).
CPCo Response Two examples to support this apparent violation were that the training records indicated that technicians had completed and passed the Health Physics practical factors training when in fact no training had been given, and that the technician qualification examination results were altered during the compilation of the exam results.
The failure to maintain accurate General
~mployee Training records was caused by an instructor inappropriately completing practical factors training records for certain contract radiation safety technicians.
The training records indicated that the technicians had completed and passed the practical factors training when in fact no training had been given.
C~rrective action for this event included the following and all corrective actions are complete:
- 1.
The event was reviewed with both contract and company instructors, emphasizing the importance of and consequences of failing to maintain accurate records.
- 2.
The instructor was asked to and did resign.
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- 3. A QA surveillance was performed of other work by the same instructor to insure that corrective actions were adequate.
No additional corrective actions were determined necessary.
- 4.
The training of other radiation safety technicians (those rece1v1ng.
General Employee Training from other instructors) was reviewed to determine if those technicians received the required training, including practical factors training. It was determined that all other technicians received the required training.
The second example of failure to maintain accurate training records was the apparent alterations of the contract radiation safety technician site specific
- radiation safety training exam answer sheets. This was identified during a QA surveillance and exam regrading effort to resolve grading errors. The exact cause of the failure to maintain accurate technician qualification records is not known, however it is attributed to weaknesses in exam grading and exam security.
Corrective actions for this event included:
- 1.
All exams were regraded. As students were identified as having failed to meet the successful completion criteria, supervision was notified to restrict them from working independently.
- 2.
Supervision was directed to review samples of the affected individuals' work to date to assess the quality of the work.
- 3. All exams administered during the spring maintenance outage by the instructor in question were regraded.
- 4.
Technicians failing qualification exams were retested.. All successfully completed the qualification exams
- 5.
A post training effectiveness survey was completed to assess the quality of technical training overall. The survey indicated that the training was effective.
- 6.
Future contract radiation safety technician training will be conducted in accordance with normal Nuclear Training Department record preparation, testing protocol, exam grading, and exam security standards.
Radiation Safety Technician qualification consists of the qualification exam and the on the job training (OJT). All techni~ians failing the written qualification exam participated in OJT. Subsequent reviews of their work have not identified any performance deficiencies. All technicians failing the written qualification exam passed their retests.
Consumers Power Company requests that the NRC exercise discretion and not issue a notice of violation for this event. It is believed that the criteria of 10 CFR Part 2, Appendix C, Section V.G.l, are met in that the events were identified by the licensee, the events are of minor significance and would normally be classified at a Severity IV or V, the events were promptly reported to the NRC Senior Resident Inspector even though no report was required, prompt corrective actions were taken when the events were discovered, and the events were not willful and could not reasonably be expected to have been prevented by corrective action from a previous violation. Regarding the willfulness of the failure to maintain accurate 2
General Employee Training records, Consumers Power Company believes that this event was due to an error in judgement on the part of the instructor, and
.should not be considered "willful" as defined.in the NRC enforcement policy.
NRC Apparent Violation No. 255/90028-03 The licensee failed to provide contract instructors, including the former instructor, with appropriate training on training department administrative controls and procedures. This included procedures that delineated the requirements for waiving training requirements.
Failure to provide indoctrination and training to assure that a suitable proficiency is achieved and maintained is an apparent violation of 10 CFR 50, Appendix B, Criteria II.
CPCo Response
- The subject instructor was provided adequate indoctrination and supervisory support to perform the function of a platform instructor. The certification process for instructors requires that they first complete the class as a student or sit through. and observe the class.
(In some instances this requirement may be waived, but the subject instructor completed the class.}
The instructor must then perform an internship with a certified instructor or conduct a performance demonstration ~ith a supervisor or certified instructor.
In either case, they.are gi~en current copies of the lesson mate~ials and shown how to process the class records.
Each of the forms they must complete have directions included with the form such that referral to the procedures is not required. Other areas of the procedures are not covered since they apply to the development of programs and lesson plans, training evaluation, procedure development and student transcripts. Regarding the issue of waiving students from the practical factors portion of General Employee Training, the subject instructor was instructed on the Company policy regarding such waivers during the certification process. Therefore, no violation of IO*CFR 50, Appendix B, Criterion II occurred.
NRC Apparent Violation No. 255/90019-05 Failure to observe high radiation area access controls as prescribed by Technical Specifications.
The example give~ to support the violation was that individuals crossed a High Radiation boundary without a radiation monitoring device or accompanied by someone qualified in radiation protection procedures, with a radiation dose monitoring device.
CPCo Response The violation of high radiation area access requirements occurred when a plant support supervisor and an auxiliary operator knowingly violated a high radiation area boundary without proper radiation monitoring as required by plant Technical Specifi~ations in order to expedite repair of the volume reduction system. *The violation is attributed to an error in judgement on the part of the. supervisor who thought he knew the radiological conditions of the area and could safely disregard the boundary.
Even though the volume reduction system was not processing waste at the time, and therefore, the area was not in actuality a high radiation area, the supervisor's decision to violate the boundary is not condoned by Consumers Power Company and was immediately addressed as follows:
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- 1. A management review board was convened immediately after the event to gather facts and determine appropriate corrective actions.
- 2.
The individuals involved received discipline. in accordance with Consumers Power Company's disciplinary policy.
- 3.
The event was discussed with other operations personnel to emphasize the importance of and consequences of failing to comply with administrative requirements.
- 4.
The volume reduction system drum fill processing sheet was revised to require notification of health physics prior to processing..This will assure better coordination between the posting of the volume reduction
- system area as a high radiation area and the actual processing of waste.
Consumers Power Company requests that the NRC exercise discretion and not
- issue a notice of violation for this event.
It is believed that the criteria of 10 CFR Part 2, Appendix C, Section V.G.l, for exercising of discretion, are met in that the event was identified by the licensee, the event is of minor significance and would normally be classified at a Severity IV or V, the event was promptly reported to the NRC Senior Resident Inspector even though no report was required,*prompt corrective actions were taken when the event was discovered, and the event was ~ot willful and could not reasonably be expected to have been prevented by.corrective action from a previous violation~.
Regarding the issue of willfulness, Consumers Power Company believes that the event was due to an error in judgement on the part of the individuals involved and should not be considered "willful" as defined in the NRC enforcement policy.
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