ML20044D032
| ML20044D032 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/05/1993 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP88362, NUDOCS 9305170084 | |
| Download: ML20044D032 (5) | |
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Btl V N IA G A R A R UMOHAWK NIAGARA MOHAWK POWER CORPORATION /NINE IA!L E POINI P O. BOX 63. LYCOfAING. NY 13093/ TELEPHONE (315) 349-2882 B. Ralph Sylvis Enecutive Vice President
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May 5,1993 NMP88362 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 RE: Nine Mile Point Unit 1 Docket No. 50-220 DPR-63 Gentlemen:
SUBJECT:
RESPONSE TO NOTICE OF VIOLATION - NRC COMBINED l
INSPECTION REPORT 50-220/93-04 AND 50-410/93-03 Attached is Niagara Mohawk Power Corporation's response to the Notice of Violation contained in the subject Inspection Report dated April 8,1993. We believe that the corrective actions described in this response have appropriately addressed the cause of this violation. If you have any questions concerning this matter, please contact me.
Very truly yours, hhd) b B. Ralph Sylvia Exec. Vice President - Nuclear BRS/JTP/ime Attachment xc:
Mr. T. T. Martin, NRC Regional Administrator, Region I Mr. W. L. Schmidt, Senior Resident Inspector Mr. R. A. Capra, Director, Project Directorate I-1, NRR Mr. D. S. Brinkman, Senior Project Manager, NRR Records Management i
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9305170084 930505
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
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i Niagara Mohawk Power Corporation
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Nine Mile Point Unit 1
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Docket No. 50-220 Nine Mile Point Unit 2
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Docket No. 50-410 f
B. Ralph Sylvia, being duly sworn, states that he is Executive Vice President-Nuclear of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the document attact ed hereto; and that the document is true and correct to the best of his knowledge, informadon and belief.
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A.'R'alph S[lviaExecutive Vice Pres /
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Subscribed and sworn before me, a Notary Public in and for the State of New York and the County of Oswego, this 5' day of May,1993 j
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MOTARY P BLIC BEVERLY W RIPKA Notary Public Stateof ht* TDI6 Quatin Oswego Ca. No. (f44 9 My Commission Esp Q
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l NIAGARA MOIIAWK POWER CORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR-63 i
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" RESPONSE TO NOTICE OF VIOLATION," AS CONTAINED IN l
INSPECTION REPORT 50-220/93-04 AND 50-410/93-03
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VIOLATION 50-220/93-04-01 During an NRC inspection conducted on March 22-26,1993, a violation of NRC iequirements was i
identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), the violation is listed below:
i Technical Specification 6.11 requires, in pait, that procedures for radiation protection be prepared and adhered to for all operations involving personnel radiation exposure. Licensee procedure AP-3.3.3 required, in part, that all radiation workers verify that proper radiation dosimetry is used in accordance with radiological postings.
Contrary to the above, on March 22 and 25,1993, radiation workers failed to verify that proper radiation dosimetry was used in accordance with the radiological postings. Specifically, on l
March 22 a worker was found in an area of the new Radwaste Building that was posted as a l
radiologically restricted area without his thermoluminescent dosimeter (TLD) and self-reading
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dosimeter (SRD), and on March 25 a worker was observed leaving the Turbine Building which was posted as a radiologically restricted area without his TLD or SRD. Radiologically
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restricted areas are posted requiring workers entering the areas to carry their assigned l
dosimetry. On March 22, the worker had left his dosimetry clipped to a radiological posting at the step-off pad on the 247' elevation of the old Radwaste Building, and on March 25 the i
worker had le.ft his dosimetry m the Turbine Building attached to a laboratory coat.
i This is a Severity Level IV violation (Supplement IV).
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L TIIE REASON FOR THE VIOLATION i
Niagara Mohawk admits to the violation as stated in Inspection Repon 93-04/93-03.
A root cause analysis was performed and found that personnel error due to poor work practices was the cause of both of the events. In the March 22,1993 event, the worker was removing
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his protective clothing at the exit of a contaminated area in the radiologically restricted area (RA). The worker removed his dosimetry and security badges, clipped them to a sign, and inadvertently left them there. In the March 25,1993 event, the worker. removed his lab coat before exiting the RA and inadvertently left his dosimetry and security badges attcched to the lab coat.
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4 ll II.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED j
Deviation / Event Reports (DERs) were written to document and develop corrective actions for-j both events. Corrective actions taken for the March 22 event were:
s The dosimetry and security badges were retrieved and returned to the worker, and the e
worker was escorted out of the radiologically restricted area. The radiation worker 1
status of the individual was suspended.
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Radiation Protection investigated the worker's travel path, area dose rates, stay times j
e and estimated exposures. Dose rates were 2-6 mrem /hr in the area the individual was j
working with dosimetry and where he left his dosimetry. Dose rates were less than 0.2 mrem /hr in the area he worked without his dosimetry. He was in the lower dose rate area without his dosimetry for approximately 15 minutes. His dosimetry was evaluated l
and no 10 CFR 20 radiation dose limits or Niagara Mohawk administrative guides were i
exceeded.
i Security determined that the worker's security badge was not used to enter any vital f
e areas during the time it was separated from the worker.
The worker was counseled about dosimetry and security badge requirements.
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The worker reattended General Employee (radiation worker) Qualification Training,.
e including a practical exercise on the use of protective clothing and dosimetry, on April j
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14, 1993. After successfully completing the training, his status as a radiation worker j
was re-instated.
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Corrective actions taken for the March 25 event were:
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The dosimetry and security badges were retrieved and returned to the worker. The e
radiation worker status of the individual was suspended.
l Radiation Protection mvestigated the worker's travel path, area dose rates, stay times e
and estimated exposures. Dose rates were less than or equal to 0.2 mrem /hr in the area
.j where the worker was without his dosimetry. He was without his dosimetry for l
approximately 5 minutes. His dosimetry was evaluated and no 10 CFR 20 radiation dose limits or Niagara Mohawk administrative guides were exceeded.
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Security determined that the worker's security badge was not used to enter any vital e
.1 areas during the time it was separated from the worker.
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CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED (Cont.)
l The worker was counseled regarding the importance of radiological controls, maintenance principles, and the use of the STAAR (Stop, Think, Ask, Act, Review) program.
l The March 22 and March 25 events were reviewed with the Maintenance Department (the worker was a member of the Maintenance Department).
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ACTIONS TA$EN TO PREVENT RECURRENCE l
Managemer.t expectations, regarding the proper wearing of dosimetry and security badges, continues to be communicated to workers by the following actions:
i A Lesson's Learned Transmittal, explaining the event and corrective actions, has been distributed to all nuclear managers.
Security has provided individual notices on all plant personnel security badges to display l
the photo identification badge on the outermost garment while in the protected area. The only exception is for personnel entering potentially contaminated areas who may wear.
the photo identification badge under protective clothing.
r This violation, and the associated Deviation / Event Reports, will be included in General l
Employee Training by June 15,1993, and remain there for 1 year.
l Management oversight of personnel adherence to proper dosimetry and security badge wear will i
continue to be monitored through 1993 by:
l Quality Assurance surveillance activities. Prior to the March 22 event, Quality l
Assurance had added dosimetry and security badge placement attributes to their surveillance checklist for work in the field.
Plant Manager's tours.
Radiation Protection Supervision oversight.
j Self-Assessment of the results of management oversight will be performed by February 1994, to I
identify if additional long-term corrective actions are appropnate.
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DATE WIIEN FULL COMPLIANCE WILL BE ACHIEVED Full complitace was achieved on March 22 and March 25,1993, when the immediate
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corrective action of returning dosimetry and seemity badges to the workers was performed.
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