ML18040A182
| ML18040A182 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/15/1996 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP1L-1112, NUDOCS 9608230214 | |
| Download: ML18040A182 (12) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9608230214 DOC.DATE: 96/08/16 NOTARIZED:
NO ACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe UTH.NAME AUTHOR AFFIZ IATION YLVIA,B.R.
Niagara Mohawk Power Corp.
RECIP.NAME RECIPIENT AFFIZIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to NRC ltr re violations noted in insp rept 50-220/96-06 on 960330-0601.C/A:made physical enhancements in Access Control Areas to.RCA.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR I
ENCL
(
SIZE:
TITZE: General (50 Dkt)-Insp Rept/Notice oi Violation Response NOTES:
DOCKET 05000220 RECIPIENT ID CODE/NAME PD1-1 PD INTERNAL: ACRS
~I~E CENTE NRRR~RC~H HHFB NRR/DRPM/PERB OE DIR RGN1 FILE 01 ERNAL: LITCO BRYCEgJ H
NRC PDR COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME HOOD,D AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 19 ENCL 19
NIAGARAMOHAWK G E N E RATION BUSINESS GROUP B. RALPH SYLVIA Executive Vice President Generation Business Group Chief Nuciear Ofscer 300 ERIE BOULEVARDWEST, SYRACUSE. NEW YORK 13202/TELEPHONE (315) 4284983 August 15, 1996 NMP1L 1112 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Nine MilePoint Unit 1 Docket No. 50-220
Subject:
Reply to Notice of Violation NRC Inspection Report No. 50-220196-06 Gentlemen:
Niagara Mohawk Power Corporation's (NMPC) reply to the Notice of Violation is enclosed as Attachment A to this letter. In the attached reply, Niagara Mohawk has admitted to the violation as stated.
Very truly yours, B. Ralp Syl 'a Chief Nuclear Officer BRS/AFZ/kap Enclosure xc:
Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Records Management 96082302k 4 960815 PDR ADOCK 05000220 8
V,
Niagara Mohawk Power Corporation Nine MilePoint UnitI Docket No. 50-220 DPR-63 REPLY TO NOTICE OF VIOLATION AS CONTAINEDININSPECTION REPORT 50-220/96-06 During an NRC inspection conducted from March 30 through June 1, 1996, a violation of NRC requirements was identified. In accordance with the NRC "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, (60 FR 34381; June 30, 1995), the violation is listed below:
Title 10, Code of Federal Regulations, Part 20, Section 20.1101, requires, in part, that licensees implement a radiation protection (RP) program commensurate with the scope and extent of licensed activities.
Procedure GAP-RRP-02, "Radiation Work Permit," Revision 04, Paragraph 3.7.4, requires that workers shall access the radiologically controlled area (RCA) using either a general, standing, or specific radiation work permit (RWP).
Paragraph 2.5 states that radiation workers are responsible for compliance with the requirements of the RWP Program.
Contrary to the above, the licensee failed to properly implement its radiation protection program procedures, as evidenced by the following examples:
On January 4, 1996, an operator breached the residual heat removal system, a contaminated system, without first notifying the RP department, as required by the RWP.
On January 8, 1996, a contractor entered the RCA without wearing a thermoluminescent dosimeter as required by RWP.
On January 22, 1996, a technician entered the RCA without wearing electronic dosimetry, as required by RWP.
On March 2, 1996, a worker entered the RCA, including a locked high radiation area within the RCA, without wearing electronic dosimetry, as required by RWP.
On April26, 1996, an individual entered the RCA, failed to sign in on an RWP, and thus failed to wear electronic dosimetry, as would have, been required by the RWP.
This is a Severity Level IVviolation (Supplement IV).
Niagara Mohawk admits to the violation as stated.
The reason for the violation is inadequate corrective actions for previous deficiencies which resulted in a failure to prevent recurrence.
A Deviation/Event Report (DER) was issued for the Notice of Violation. A formal root cause was performed and determined that the managerial methods for monitoring of activities did not identify comprehensive corrective actions.
Immediate corrective actions applied for each specific event have been satisfactory in preventing recurrence by the individuals involved, but these corrective actions failed to prevent recurrence of similar deviations.
The specific events involved access control problems resulting in no additional exposures, and system breaches resulting in no spread of contamination.
Although the radiological impact of these individual events is very low, Niagara Mohawk recognizes that previous corrective actions were not sufficiently comprehensive, and the importance of self-checking and cross-checking to ensure conformance with Radiation Protection policies and practices was not adequately disseminated to workers.
As noted in the inspection report, these deficiencies were self-identified and the "effectiveness of the corrective action to prevent recurrence willtake time to be assessed."
Niagara Mohawk believes that the self-identification of these deficiencies is the result of management's emphasis on self-assessment to promote continual improvement.
Because of the low rate of these types of human errors, Niagara Mohawk concurs with the inspection report observation that the effectiveness of the corrective action can only be assessed over a period of time. As discussed below, Niagara Mohawk willbe monitoring this trend and taking appropriate actions based on the results of this monitoring.
DERs had been previously issued at the time of the occurrence for each of the specific instances noted as examples in the Notice of Violation. The fo11owing corrective actions have been taken as a result of these cases, and they have been effective in preventing recurrence by the individuals involved:
Physical enhancements were made in the Access Control Areas to the RCA.
Standdowns were conducted to emphasize Access Control requirements.
Management oversight and attention was increased in the area of radiation worker conformance with radiological controls.
2.
The individuals involved in the specific occurrences were counseled by Radiation Protection personnel.
These corrective actions have resulted in an improving trend for NMPC site radiation worker performance.
This trend is determined by comparing the instances of inappropriate radiological work practices to the total number of hours logged on to RWPs used on the site.
The self-assessment process willinclude a review of this information, and willcontinue to evaluate the effectiveness of the corrective actions based on performance trends.
Subsequent corrective actions based on these self-assessments willenhance the program as appropriate.
Radiation Protection policies and practices willcontinue to be emphasized with radiation workers.
For the next 1S months, senior management expectations in this area willbe reinforced at least quarterly through communications disseminated to site radiation workers.
2.
Electronic Dosimeter Readers (DR-200's) have been equipped with an audible alarm which activates ifthe electronic dosimeter is not removed from the reader in a timely manner after RCA entry is granted.
Since installation of the alarm, there have been no repeat instances of workers leaving their electronic dosimeters in the reader and entering the RCA.
3.
Further human factor enhancements willbe evaluated, and ifappropriate, implemented for access control evolutions to facilitate self-checking and cross-checking actions.
Completion Date:
December 31, 1996.
4.
During peak RCA activities, such as refueling outages, the station willdedicate specific personnel to enhance the oversight of access control and RCA entry. The effectiveness and the potential for further implementation of this action willbe evaluated following the next Unit 2 refueling outage.
Completion Date:
November 30, 1996.
The actions that Niagara Mohawk has taken have reduced the number of personnel errors related to the radiation protection program over the short term.
Niagara Mohawk's efforts to
'strengthen the radiation protection program willcontinue to focus on an effective self-assessment process.
The future collection and evaluation of data willbe used to assess the effectiveness of these actions and programmatic changes, and willenable Niagara Mohawk to proactively develop further program enhancements ifneeded.
Niagara Mohawk believes that the self-identification of personnel errors has, in itself, resulted in a reduction of personnel performance issues in this area.
Niagara Mohawk willcontinue to promote the self-identification of concerns and issues by the work force and believes that this
atmosphere in conjunction with the periodic re-emphasis of the program's importance and the enhanced human factor controls willreduce the frequency of these deficiencies.
Niagara Mohawk has re-established full compliance upon completion of the corrective actions for each individual event described in the Notice of Violation.