ML20028H703
| ML20028H703 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/21/1991 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-938, NUDOCS 9101290004 | |
| Download: ML20028H703 (5) | |
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Donald C. Shohen 300 MaJosi Avenue Vce PreWed Nuclear MM. OH 43%20001 Das Bnse (419)to 2300 Docket Number 50-346 4
License Number NPF-3 Serial Number 1-938 January 21. 1991 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Subjec t :
Response to Nuclear Regulatory Commission Inspection Report 50-346/90022 Gentlement Toledo Edison received the subject inspection report (Letter Log Number 1 2408) dated December 12, 1990.
In this report, the Nuclear Reguistory Commission (NRC) staff requested that they be informed of the actions Toledo Edison has taken or plans to take to preclude recurrence of potentially significant radiological controls events.
The attachment to this letter providet a synopsis of the Toledo Edison management actions initiated to resolve these concerns.
If you have any questions regarding this matter, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Very trgl yours, dM-g NKP/mmb Atta.chment cci P. H. Byron, DB-1 NRC Senior Resident Inspector A. D. Davis,. Regional Administrator, NRC Region III D. C. D1 Ianni, DB-1 Senior Project Manager Utility Radiological Safety Board 9101290004 910121 PDR ADOCK 05000346 Cl PDR g
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F oocket Hu:h>< 30-346 License Nu bar NPF-3 Sartal Nu bar 1-938 Attachment Page 1 SYNOPSIS OF TOLEDO EDISON MANAGEMENT ACTIONS j
During the handling of contaminated material on October 18, 1990, vorkers at the Davis Besse Nuclear Power Station (DBNPS) received intakes of radioactive contaminants.
While these intakes were all vell belov legal limits, Toledo Edison management determined that the number of recent events involving radiological controls practices was unacceptable and a Management Corrective Action Report (MCAR) vas initiated.
Each event was well investigated at the time of occurrence and corrective actions vere taken.
flovever, the recurrence of related events suggested the possibility of a I
programmatic weakness in the DBNPS Radiological Controls (RC) program.
The purpose of the MCAR was to provide a comprehensive review of radiological j
controls-related events since January 1, 1990 to determine if they resulted l
from one or more similar causes.
If the causes vere similar, actions to correct any programmatic veaknesses vould be recommended to Toledo Edison-management.
To accomplish the stated purpose of the MCAR, an internal assessment of the RC program was performed by a team of selected RC department personnel.
These personnel represented a cross-section of the RC organization with regard to experience and organizational levels.
In addition, a second, independent assessment was conducted by the Independent Safety Engineering Group (ISEG) which utilized a representative from the Institute of Nuclear Power Operations (INPO) trained in the evaluation of RC programs and human performance effectiveness issues.
The assessment-teams used NUREG-0855,
" Health Physics Appraisal Program" and INPO 88-010, " Guidelines for Radiological Protection at Nuclear Power Stations" as guidance documents, and examined both technical and human performance issues.
Following the completion of the two independent assessments, the teams presented the 1
results and recommendations (or corrective actions to Toledo Edison management and an action plan was developed.
The common root cause of several of the recent radiological controls events was determined to be inadequate communications within the RC department.
Symptoms of this root cause include the following:
Vrltten guidance, such as procedures or instructions, are often overly burdensome, conflicting and lack an appropriate level of detail. This allows for inconsistent or incorrect interpretations of procedural and administrative requirements.
j i
l Effective feedback to PC department personnel is sometimes not l
timely and not fully understood by the individuals.
This leads to 7
an attitude within-the department that an individual's suggestions for program enhancement often go unheeded by management.
Departmental goals, objectives and performance standards are not 1
always effectively communica+ d and understood at all levels of the RC department.
As a result, che organization's collective experience-is not always effectively passed on to less experienced individuals.
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Dockot Hu:ber 50-346 Lic:nsa Nu:ber NpF-3 S2 rial Hu:ber 1-938 Attachment Page 2 The responsibilities of various groups and individuals within the RO department are not vell defined and understood by all members of the organization.
To correct the root cause and symptoms described above, a number of specific corrective actions have been taken by the RC department and others have been scheduled for completion in the near future. Toledo Edison expects these changes to better define responsibilities of individuals in the RC organization, better communicate performance standards and management expectations for RC department personnel, and reduce confusion by eliminating conflicting performance and procedural requirements.
A task group vill be set up by the RC department to review the departmental procedures and identify prob Mm areas.
Specific attention vill be given to the quantity of procedures, procedure interactions, procedure conflicts, and use of instructions for specific tasks in lieu of more generalized procedural steps.
Recommendations fer changes to the procedures vill be made to the Hanager -
Radiological controls by March le 1991.
Review of the recommendations and implementation of appropriate changes vill be completed by the start of the neventh refueling outag- (7RFO).
As a long term corrective action, the RC department at DBNPS is conducting periodic participative management sessions. These sessions vill have a facilitator independent of the RC staff.
During these sessions, the staff are encouraged to share their ideas and experiences to improve the quality of work and enhance communications within the department.
Quarterly reports vill be issued to Toledo Edison management to monitor the effectiveness of the participative management process.
The assessments also identified weaknesses in the Radiation Awareness Reporting program, the Radiation Vork permit program, radiological surveys, and labeling of radioactive materials.
Specific actions to strengthen these areas are described below.
The Radiological Awareness Reporting (RAR) program was established in 1987 to provide a formal mechanism of communication with RC Hanagement regarding radiological work deficiencies, concerns or suggestions. This program vill be improved in the areas of timeliness of responses, follov-up of corrective action, establishing RAR priority, and the quality of responses. The following program enhencements have been or vill be implemented:
Until sufficient program improvements are noted, the Har qar -
Radiological Controls vill review all RARs prior to closeout to ensure performance standards are set, understood and enforced.
This has been implemented.
The backlog of open RARs vill be prioritized and an action plan to reduce the RAR backlog vill be established. All RARs greater than 60 days old are expected to be closed prior to March 31, 1991.
Any exceptions must be approved by the Manager -
Radiological Controls.
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Docket Nu:bar 50-346 Licenso Nu2b2r NPF-3 i
S2 rial Nu:b2r 1-938 r
Attachment 4
Page 3 RARs vill be revieved with the originator folloving closeout.
This has been implemented.-
A specific member of Radiological Controls department has been designated accountability for the receipt, processing and follov-up of RAR documentation.
Root cause evaluations and corrective action recommendations for RARs and PCA0Rs vill include more participation by personnel (and their supervisor (s)) involved in the deficiency.
This has been implemented.
The Radiation Vork Permit program (RVP) is being improved to better control work in the radiologically controlled areas (RCAs) of the plant.
The improvements are mainly in the areas of reduced use of general RVPs, use of more task specific instructions, and providing more specific guidance with respect to termination of an RVP.
Specific improvements are as follows:
All RVPs shall require a second management review and signature.
This vill normally be performed by the RC ALARA/ Rad Engineering Unit. The purpose of the review is to ensure that adequate controls are instituted for the work, that specific guidance is given for controlling the work activities, and that an RVP expiration date is specified. This has been implemented.
Expiration dates vill be specified for all RWPs and entered into a computer tracking system to provide automatic termination of an RVP. This has been implemented.
RVP instructions vill be more specific to better control work inside the RCA, and to encure adequate planning of multi-task and lengthy work assignments. These instructions vill include appropriate varnings to workers about any potential for changing radiological conditions.
Both the RC Operations and the RC ALARA/ Rad Engineering unitt vill review all' work instructions for work inside the RCA to identify when a specific RVP vill be utilized.
This has been implemented.
Discussions vill be held with RC department first line supervisors and RC testers:to emphasize that the RC department is responsible for controlling the work from a radiological standpoint and is not responsible for ensuring that the vork-is expedited.
RC testers vill be instructed and expected to be more assertive when providing direction to other vork groups. This has been completed.-
The Manager - Radiological Controls vill be responsible for the-review of a sample of RVP packages to ensure performance standards are followed.
This has been implemented.
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i, Docket Number $0-346 Lic2nso Numb 2r NPF-3
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Serial Number 1-938 Attachment Page 4 The RC Department vill perform a comprehensive evaluation of radiological survey activities. This study vill focus on the adequacy of the existing survey program and vill be modified to eliminate duplicative and unnecessary l
surveys. This vill be completed by April 1, 1991.
I A sample of radioactive materials packages generated during the sixth refueling outage vill be inspected to check the accuracy of in-use labels.
l An evaluation of the results of this inspection vill be performed to i
determine if further inspections are necessary.
This initial inspection vill be completed by March 1,_1991.
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