IR 05000245/1997002

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/97-02, 50-336/97-02 & 50-423/97-02 Issued on 970624.Actions Will Be Examined During Future Insp

ML20217Q000
Person / Time
Site:	Millstone
Issue date:	08/14/1997
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carns N NORTHEAST NUCLEAR ENERGY CO.
References
50-245-97-02, 50-245-97-2, 50-336-97-02, 50-336-97-2, 50-423-97-02, 50-423-97-2, NUDOCS 9708290104
Download: ML20217Q000 (3)

Text

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August 14, 1997 Mr. N. S. Carns, Senior Vice President

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snd Chief Nuclear Officer Northeast Nuclear Energy Company PO Box 128 Waterford, CT 06385 SUBJECT: COMBINED INSPECTION REPORT NOS. 50 245/97-02,50-336/97 02, AND 50-423/97-02 (REPLY)

Dear Mr. Carns:

This letter refers to your July 25,1997 correspondence, in response to our June 24,1997 letter.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, ORIGINAL SIGNED BY:

Jacque P. Durr Chief, inspections Special Projects Office Office of Nuclear Reactor Regulation Docket Nos. 50 245;50-336:50-423 200087 ,

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IllE ElliJil,E RJM 9708290104 970814 PDR ADOCK 05000245 O PDR

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Mr.- N. : 2-cc:-

M. H. Brothers, Vice President - Millstone, Unit 3 J. McElwain, Unit 1 Recov< ry Officer

- M. Bowling, Jr., Unit 2 Recovery Officer D. M. Goebel, Vice President, Nuclear Oversight J. K. Thayer, Recovery Officer, Nuclear Engineenng and Support P. D. Hinnenkamp, Director, Unit Operations =

F. C. Rothen, Vice President, Work Services J. Stankiewicz, Training Recovery Manager R. Johannes, Director - Nuclear Training

- cc w/cy of Licensee Response Letter:

_ L. M. Cuoco, Esquire J. R. Egan, Esquire V. Juliano, Waterford Library .

' J. Buckingham, Department of Public Utility Control S. B. Comley, We The People State of Connecticut SLO Designee D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN J. M. Block, Attorney, CAN -

S. P, Luxton, Citizens Regulatory Commission (CRC)

Representative T. Concannon E. Woollacott, Co Chairman, NEAC 1 ,

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Mr. N. Distribution:

Region I Docket Room (with ggpy of concurrences)

Nuclear Safety Information Center (NSIC)

PUBLIC -

FILE CENTER, NRR (with Orioinal concurrences)

NRC Resident inspector B. Jones, PIMS/ DISP M. Kalamon,- RPO, RI W. Lanning, Deputy Director of Inspections, SPO, RI D. Screnci, PAO W. Travers, Director, SPO, NRR

- J. Andersen, PM, SPO, NSR M. Callahan, OCA R. Correia, NRR W. Dean, OEDO l

- S. Dembek, PM, SPO, NRR

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G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR D. Mcdonald, PM, SPO, NRR P. McKee, Deputy Director of Licensing, SPO, NRR L. Plisco, Chief, SPO, NRR S. Reynolds, Technical Assistant, SPO, NRR t inspection Program Branch (IPAS)

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DOCUMENT NAME: 1:\ BRANCH 6\REPLYLTR\9702 REP To seesive e copy of this document. Indsete in the boa: *C" = Copy without attachment! enclosure 'E' - Copy with attachment 4nc40su,e ,

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OfflCE Rl/ ORS [E Rl/ ORS)/4 / l Rl/DRP- lE I NAME- JFuria nny JWhite#" J0urry u s DATE 08/05/97 08/nj /97 08//<//97 08/ /97 0FF/CIALRECORDCOPY

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Nuclear Energy m,,one sa, ro.n swoo Nonheut Nuclear EnerFy Company P.O. Bos 128 Weierford. CT 06385-0128 (860) 447 1791 Fu (860) 444 4277 The Northeast Utihties Systera JUL 2 51997 Docket tios. 50-245 50-336 )

50-423 i

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B16619 Re: 10CFR2.201

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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Facility Operating License Nos. DPR-21, DPR-65, NFP-49 Reply to a Notice of Violation Inspection 50-245/97-02: 50-336/97-02: 50-423/97-02 in a letter dated June 24,1997,W the NRC transmitted the results of an inspection conducted at the Millstone Station from March 11,1997, to May 19,1997. The NRC '

Inspection Report concluded that Northeast Nuclear Energy Company (NNECO) failed to properly impleme..' our rad;otion protection program as demonstrated by having five instances of personnel entering the RCA without wearing a functional electronic dosimeter or TLD, These included one instance at Millstone Unit No.1, three instances at Millstone Unit No. 2, and one instance at Millstone Unit No. 3.

On behalf of Millstone Unit Nos.1,2, and 3, Attachment 1 provides NNECO's reply to the Notice of Violation pursuant to the provisions of 10CFR2.201.

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• Wayne D. Lanning to Bruce D. Kenyon,'NRC Combined inspection 50-245/97-02; 50-336/97-02; 50-423/97-02 and Notice of Violation," dated June 24,1997.

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. ; U.S. Nuclear Regulatory Commission . 3 B1661thPage 2 i

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Commitments

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The following are NNECO's subsequent. actions which are committed to by;this l response:

R B16619 1 A station-wide trending program, which will provide a tool to assess the

.. effectiveness of near term corrective actions for human performance, will  :

be in place by September 30,1997.  ;

B16619 - 2 The long term effectiveness of corrective actions will be evaluated by

. performing a self-assessment. This will be completed by March 31,1998.

LShould you have any questions regarding this submittal, please contact Mr. Ravi Joshi }

, at (860) 440 2080.

. Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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Senior Vice President and

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Chief Nuclear Officer

!' Attachments (1)

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cc- H. J. Miller, Region i Administrator S. Dombek, NRC Project Manager, Millstone Unit No.1 .

- T. A Eastick, Senior Resident inspector, Millstone Unit No.1 D. G. Mcdonald Jr., NRC Senior Project Manager, Millstone Unit No. 2

. D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 J. W. Andersen, NRC Project Manager, Millstone Unit No. 3

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A. C. Cornel Senior Resident inspector, Millstone Unit No. 3 '

.W. D. Travers, PhD., Director, Special Projects Office - ,

.. -W. D. Lanning, Deputy Director, inspections, Special Projects Office .

' J. P. Durr, Branch Chief, inspections, Special Projects Office

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Docket Nos. 50-245 50-336 EQ:d23 .

B16619 ,

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Attachment 1 Millstone Unit Nos.1,2, and 3 Facility Operating License Nos. DPR-21, DPR45, NFP-49 i

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Reply to a Notice of Violation NRC Combined Inspection Report 50-245/97-02,50-336/97-02 and 50-423/97-02

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July 1997

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. U.S. Nucirr R:gulatory Commission B16619\ Attachment 1\Page 1 Millstone Unit Nos.1,2, and 3 Facility Operating License Nos. DPR 21, DPR-65, NFP-49 -

Reply to a Notice of Violation Restatement of Violation

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Title 10, Code of Federal Regulations, Part 20.1101 (10 CFR 20.1101) requires, in part, that licensees develop and implement a radiation protection program. Paragraph ,

1.1 of procedure RPM 5.2.2, " Basic Radiation Worker Responsibilities," r0 quires, in part, that workers entering the radiologically controlled areas (RCAs) con; ply with instructions provided by the radiation protection staff, including those instructions contained in radiation work permits (RWPs). All entries to the RCA require that station radiation workers be signed in on a general or specific radiation work permit (RWP)

and wear a functioning digital alarming dosimeter and thermoluminescent dosimeter (TLD). i i

Contrary to the above, five instances of personnel entering the RCA without weanng a )

functional electronic dosimeter or TLD were identified. These include orso '.1 stance in i Unit 1 on April 15,1997; three instances in Unit 2, one each on March 5,1997, March j 7,1997, and April 15,1997; and one instance in Unit 3 on April 29,1997.  !

l This is a Severity Level IV violation (Supplement IV) for Docket Nos. 50-245, 50-336, !

and 50-423.

Reason For The Violation Northeast Nuclear Energy Company (NNECO) agrees with the cited violation. This violation was caused by inadequate human performance and was a repeat of the same type of problems identified by Notice of Violation 50-336/97-01-09.

Corrective Steps Taken and Results Achieved A Condition Report (CR), " Adverse Trends in Personnel Performance," was written on May 6,1997, to identify common / root causes and recommend corrective actiona with regards to adverse trends in personnel performance. The adverse trends in human performance were seen in Health Physics issues (lack of proper dosimetry). A Common Cause Analysis was conducted and the following root causes were identified in the radiation protection program area:

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Root Cause 1 - Inconsistent reinforcement of site performance expectations by managers and supervisors.

Root Cause 2 - Failure of management to effectively establish and communicate a site accountability system.

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- U.S. Nuclear Regulatc y Commission B16619\ Attachment 1\Page 2

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Root Cause 3 - Inconsistent work performance coaching and mentoring by managers and supervisors.

Root Cause 4 - Work processes are complicated and difficult to comprehend, Corrective action plans are in place to address each root cause in the long term. The following corrective actions have been taken to date:

. Each work group onsite is using the Condition Report (CR) system to formally document adverse conditions in dosimetry compliance to facilitate tracking, trending, and management review for this issue.

. Each Millstone unit management has conducted management briefings with personnel to emphasize dosimetry compliance expectations with their respective radiation worker populations, in addition, briefings on radiological issues have been presented to craft personnel by senior Health Physics and station management personnel to make field workers aware of radiological compliance deficiencies and worker expectations, e Millstone Station has reduced the number of entry points into the Radiological Controlled Areas (RCAs),

• The radiation worker training program has increased emphasis on dosimetry requirements to radiation workers. Also, Health Physics technicians have been integrated into practical factor training to assist the training department instructors in delivering information to radiation workers, e Mechanical one way turnstiles have been ordered and are being introduced at select RCA control access points, to serve as additional defense in depth barriers to help achieve optimum compliance.

. A multidiscipline Common Cause Analysis has been completed which determined failure mechanisms and recommended corrective actions for Health Physics compliance issues.

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. U.S. Nuclear Regulatory Commission B16619%ttachment 1\Page 3

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Results to date:

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Error rate = RCA Entry Er orstrotal RCA Entries The corrective actions completed to date have had a beneficial effect in minimizing ,

dosimetry compliance events at Millstone Station. Our goal is to have zero dosimetry compliance issues. Our actual performance during the month of June through July 23, 1997 documented that one person entered the RCA without an electronic dosimeter out of 90,842 entry events (0.00001 error rate). While we have not met our goal of zero dosim9'.ry infractions, this indicates a favorable trend over our previous year to date ,

performance. It is expected that continued emphasis will help eliminate dosimetry non-compliance issues.

The Corrective Steps That Will be Taken to Avoid Further Violations NNECO will continue to monitor and trend Millstone Station radiation protection program compliance by use of a station-wide trending program and will evaluate the long term effectiveness of corrective actions by performing a self-assessmer.t.

Date When Full Compliance Will be Achieved -

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NNECO is currently in full compliance with the requirements of.10 CFR 20.1101 and Paragraph 1.1 of procedure RPM 5.2.2, " Basic Radiation Worker Responsibilities."

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