ML20212F038
| ML20212F038 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/24/1997 |
| From: | Rang J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-155-97-11, NUDOCS 9711040150 | |
| Download: ML20212F038 (4) | |
Text
- - _,
00NSCEN09sEner)gy A CMS trergy Cwywy og th h F%mt Nxicat 1%nt Renneek R M 1OM W3i North
! M Ce e ctAtana w Ctwivest MI49??0 October 24, 1997 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 0001 1
- l)CKET 50155 LICENSE DPR 6 BIG ROCK P0JNT PLANT REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 97011, i
During a routine NRC inspection conducted from September 2, 199/. through
~
September 5,1997, one violation of NRC requirements was identified and forwarded by letter dated October 6, 1997.
The violation concerns a maintenance worker that laid down for several minutes in a contaminated, low dose area while waiting to participate in reactor head de tensioning operations. Even though his behavior was ina>propriate, the contamination levels were low, and he did not contaminate 11mself.
Consumers Energy Company agrees with the violation as stated.
Pursuant to the direction provided in the report, find attached a Reply to the Notice of Violation. The proposed corrective actions are intended to address the concerns expressed by the NRC Inspectors, and to prevent recurrence of similar incidents.
N (1amesSRang how t
~
N q
N y
3usinessandLicensqhanager I
CC:
Administrator. Region 111. USNRC NRC Resident inspector - Big Rock Point
)
NRR Project Manager - OWFN USNRC ATTACHMENT c 'j D C'd '
p%8mm8ljj.
(
ATTACHMENT CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50 155 REPLY TO A NOTICE. OF VIOLATION INSPECTION REPORT 97011 Submitted October 24, 1997 2 Pages 1
REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 97011 Violation 97011 01 As a result of an inspection conducted September 2-5, 1997, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Proce%re for NRC Enforcement Actions. " NUREG-1600. the violation is listed below:
Technical Specifitation 6.11 requires, in part, that procedures for personnel radiation protection shall be adhered to for all operations involving personnel radiation exposure.
Step 10 of Attachment 1. " Individual Responsibilities for Proper Radiation Protection." of Adninistrative Prc:edure 5.F. ' Radiation Work Permit." (Revision 12).
Instructs workers to not unnecessvily contact contaminated surfaces with their bodies. tools or equipw'.+
Jnd to not disturb such surfaces, which could spread contamination t <
ate airborne radioacttvity.
Contrary to the above, on September 2. 1997, a maintenance worker preparing to participate in reactor head detensioning operations laid down in a contaminated area for several minutes while waiting for other workers to cortplete a task.
This is a Severity Level IV violation (Supolement IV).
Consumers Energy Company agrees to the violation as stated.
- 1. Feason for the violation.
The reactor head detensioning and removing operation involves a coordinated effort by those working the job. Due to the nature of the job, workers will experience periods of inactivity while waiting to perform their job responsibilities. In some cases, it is difficult.to determine the length of time between these periods: however the worker is expected to remain close at hand (by waiting in a low dose rate area) u that delays can be minimized. In this worker's case, he was fully dressed out in anti-contamination clothing and was waiting in a low dose area for less than 10 minutes for other workers to complete their assigned task. No chairs or benches had been,"ovided for workers in the low dose waiting area. When faced with this situation in the past, workers took it upon themselves to determine what worked best in a particular situation. Depending on the individual and the length of the job.
laying down or reclining against a wall in a low dose rate area was determined
. to be an option in lieu of no chairs or benches. Radiation Protection Technicians. Maintenance Supervisors, and Plant Management accepted the practice since it did not. lead to an increased incidence of personnel contaminations. Management failed to establish the appropriate radiation pcc'ection culture. This practice can por an unnecessary risk to the workers, and will not be tolerated at the station in the future, l
l l
L l
L
. REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 97011
- 11. The corrective stens that have been taken and the results achieved.
The worker involved was counseled on appropriate behavior within a contaminated area. The work-crews were also briefed on this situation.
Management also directed that if long delays are anticipated, seating area in the low dose waiting area would need to be provided. or leaving the contaminated area would be required. These expectations were reiterated during the pre-job briefings for the remainder of the maintenance activity.
The Big Rock Point Nuclear Power Plant Policy was also revised to provide direction for worker rest in contaminated areas and now states the following:
When workers in contaminated areas require rest. the following items are to be considered:
- Waiting in a low dose area versus leaving the work area.
- Providing appropriate facilities for resting such as chairs or benches.
- Avoiding contact with contaminated surfaces.
In addition. facility employees were made aware of the policy change and managements expectations that laying or leaning on contaminated surfaces is not aporopriate except in emergency circumstances.
Ill. The corrective stens that will be taken to avoid recurrence.
No further actions are required at this time. The corrective steps previously discussed are intended to preverit recurrence.
IV. The date when the facility will be in full comnliance.
The facility is currently in full compliance,
\\