05000443/LER-2006-002

LER-2006-002, Noncompliance with the Requirements of Technical Specification 6.8.1.2.a

Docket Number
Event date:
Report date:
Initial Reporting
ENS 42397	Other Unspec Reqmnt
4432006002R00 - NRC Website

I. Description of Event

At approximately 0800 on March 8, 2006 it was discovered that the annual report tabulating exposure by work and job function required by TS 6.8.1.2.a was not submitted by the March 1 due date. The requirement to submit the report was tracked by Seabrook Station's Condition Reporting System. In early February, a Regulatory Compliance Analyst contacted Radiation Protection (RP) Records for the report. RP Records personnel contacted the NRC's Radiation Exposure Information and Reporting System (REIRS) regarding report submittal and was told reports were due April 30. Based on the information relayed from REIRS, the Regulatory Compliance Analyst inappropriately changed the due date in the condition report to April 30 without reviewing Technical Specification 6.8.1.2a. On March 8, while confirming due dates for April correspondence, it was discovered that the report known at Seabrook Station as the Annual Report on Radiation Exposure by Job Function was required to be submitted by March 1. A 24-hour report (EN 42397) was made to the NRC for a violation of an administrative technical specification.

II. Cause of Event

The cause of the event is personnel error on the part of the Regulatory Compliance Analyst due to inadequate qualification, validation and verification (Q V & V) of information provided by RP personnel.

III. Analysis of Event

The Regulatory Compliance Analyst did not use human performance tools to verify the due date of the Technical Specification required report prior to changing the due date on the condition report.

The failure to submit the report on schedule was an administrative error that did not affect the operation of the Unit. Therefore, there were no safety consequences.

IV. Corrective Action All condition reports for Technical Specification required reports were reassigned to the Regulatory Compliance Supervisor and due dates were verified to be correct.

Administrative controls were added to prevent changing due dates for regulatory required reports.

The Radiation Protection Department procedure will be revised to include Technical Specification information and due dates.

A case study will be prepared for this event and presented to the Regulatory Compliance Department.

V. Additional Information

None Similar Events There have been no other occurrences of a report required by Technical Specifications not being submitted by the due date.

Manufacturer Data Not Applicable