ML20065K810

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Systematic Assessment of Licensee Performance Notes Re Facility Evaluation for Feb 1980-Oct 1981
ML20065K810
Person / Time
Site: 05000000, Nine Mile Point
Issue date: 01/31/1981
From:
NRC
To:
Shared Package
ML082180535 List:
References
FOIA-82-261 NUDOCS 8210080139
Download: ML20065K810 (5)


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NINE MILE POINT 1 Evaluation Period: 2/1/80-1/31/81 I.

General y

The licensee expanded the onsite staff to address the weaknesses identi-f; fied during routine inspections and during the Health Physics Appraisal.

f;A The licensee hired a full time Emergency Planning Coordinator; authorized T,

a 50% increase in the size of the HP staff; added eight contractor HPs; and, retained the services of a General Electric consultant to assist w.

_ 97, with health physics procedure updates.

Additionally, the licensee has i

added two radwaste operators per shift; and instituted a systematic M, i ;..

program to upgrade performance in the health physics area, with monthly I

status reports submitted to the NRC.

-94 The licensee revised procedures governing the flow of information within 2;

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+he corporate and onsite organizations to address the management controls M

weaknesses identified during the NRC investigation associated with the

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licensee's failure to meet a TMI Short Term requirement.

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Specific o

.. :r jEN Contention ny 4f

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. "The Nine Mile Point facility displayed evidence of weaknesses in four

-J@[ ~,. g functional. areas.

Those areas were: radiation protection, emergency

,g preparedness, radioactive waste managment, and management controls."

These contentions are addressed as follows:

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' Radiation Protection (See Contention A)

Emergency Preparedness (See Contention B) l Radioactive Waste Management (See Contention C)

Management Controls (See Contention D)

'Contentiori A "The Radiation Protection Area was characterized by items of noncom-

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pliance and inadequacies in major areas of the licensee's Health Physics Program.

Escalated enforcement action was taken to assure licensee corrective actions."

1.

Basis References The Health Physics Appraisal in October 1980 IE Report 50-220/

3 identified eleven items of noncompliance (in-80-11 fractions) anil forty-four separate items re-quiring correction to achieve an acceptable program. These findings indicated weaknesses in the areas of personnel selection, qualifi-cations and training, exposure control, radio-

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8210080139 820712 PDR FOIA UDELLB2-261 PDR

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logical surveillance and ALARA program imple-mentation.

In addition, it was determined that there was inadequate technical depth in the Radiation Protection organization, the staffing, and some procedures.

2.

NRC Actions An Immediate Action Letter was issued on 10/10/80 NRC Region

W October 10, 1980 (IAL 80-38) requiring the I letter (IAL 80-38) licensee to develop and submit an Action

'~~ i Plan detailing milestones and schedules to upgrade the Radiation Protection Program on a priority basis.

The NRC reviewed monthly progress reports summarizing efforts

& 'O in upgrading the Radiation Protection Program W~~

l which the licensee has submitted since January I

1, 1981. Review of these monthly reports will

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continue until the upgrading is completed.

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Licensee Corrective Action W 9 SC f The licensee submitted an Action Plan, 11/26/80 Licensee

{g3 with milestones and schedules, to upgrade letter

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-yp, the Radiation Protectiorj Program.

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Action Plan was developed with the assis-

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tance of a specialist from the~G'eneral

[_Qf Electric Company who was working on-site since October 28, 1980. A fifty per-F- ~ '-

cent increase in the size of the technical staff was authorized by the licensee to l

allow for training and for the increased workload the upgraded programs would en-tail. Additionally, the radiation protection-technicians were augmented by eight contrac-tor health physics technicians.

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Contention B "The licensee had significant weaknesses in... emergency preparedness... "

1.

Basis References During the Health Physics Appraisal, weak-IE Report 50-220/

nesses were identified also in four major 80-11 areas of the Emergency Preparedness Program:

Emergency Organization, Training / Retraining, Emergency Facilities / Equipment, and Emer-gency Procedures.

There were 21 specific

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fin' dings ~within these areas.

In addition,

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a finding concerning the adequacy of the i

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High Range Interim Effluent Stack Monitor was identified. This finding, which resulted in a civil penalty, is discussed in Conten-7 tion D.

7 2.

NRC Actions 3/.

9 A report was issuad identifying twenty-one 3/2/81 NRC letter fq specific actions required to achieve an ac-

, c JN ceptable program.

NRC continues to monitor

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licensee's corrective actions. An Emergency

!YO Preparedness Appraisal inspection has been scheduled.

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Licensee's Corrective Actions 35$d

- 41 The licensee committed to take actions to 5/7/81 Licensee address the specific NRC findings. Addi-letter

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tionally, the licensee implemented a new

'c, revision to the Emergency Plan and imple-h'j:;M menting procedures in order to update the

@y program as required by 10 CFR 50 and NUREG 0654.

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' contention C "The licensee had significant weaknistes in the areas of... Radio-

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active Waste Management.".

References l

1.

Basis The Health Physics Appraisal determined IE Report 50-220/

i that the overall Radioactive Waste Manage-80-11 ment program responsibility was not vested in a single individual, but rather in several -

individuals. The responsibilities and inter-actions were not documented.

Significant weaknesses identified in the Radioactive Waste Managerc.ent program included: the indi-vidual designated as the Radwaste Coordinator did not have adequate staff or the authority commensurate with his assigned chties; the training for personnel assigned tasks related l

to Radioactive Waste Management was not suffi-cient; Waste Handling proceoures were not ade-quately established, implemented or reviewed; and the Site Quality Assurance Department did not provide sufficient active participation in activities relating to radioactive waste pack-aging and shipment.

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2.

NRC Actions An Immediate Action Letter was issued on 10/10/80 NRC Region October 10, 1980 (IAL 80-38) requiring the letter (IAL 80-38) licensee to develop and submit an Action Plan detailing milestones and schedules to upgrade the Radiation Protection Program.

The required Action Plan was directed to include Radioactive Waste Management.

31 Licensee Corrective Action The 1icensee submitted an Action Plan, 11/26/80 Licensee

- with milestones and schedules, to up-letter; grade the Radioactive Waste Management program as part of the overall Action 5/7/81 Licensee Plan for upgrading the Radiation Pro-letter j

tection Program.

Waste Handling procedures were developed, re-j viewed, approved and implemented by the licensee.

j The Radwaste Operations Coordinator will be g.

assigned two dedicated operators per shift, tl' d.+,)

effective 8/31/81, who will be trained in

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their assigned tasks.

U Contention D

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P'j' "An inadequate installation prevented' full compliance with the require-ments for an increased range radiation monitor pursuant to the short term requirements of the TMI Lessons Learned.

Licensee management failed to properly identify, correct and report this inadequate installation which resulted in escalated enforcement action by the NRC."

1.

Basis References During a'special, unannounced inspection con-IE Reports 50-220/

ducted in October-November, 1980, the NRC 80-17 and 80-18; determined that the licensee failed to comply 11/26/80 NRC let-with the short term recommendations of Item ter, EA 81-08; 2.1.8.b of NUREG 0578 "TMI Lessons Learned 1/2/80 NRC Show Task Force Status Report and Short Term Recom-Cause Order; mendations." The recommendations in this re-1/22/80 Licensee por,t were made mandatory by an NRC Show Cause letter Order, dated January 2, 1980. The inspection, and

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a subsequent NRC investigation, identified the fact that an acceptable method for quantifying ncble gas releases during accident conditions was not in place at the facility. Moreover, the li-censee failed to convey this information accu-


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rately to the NRC, but indicated in the January 22, 1980 response to the NRC Show Cause Order that the short term requirements of Item 2.1.8.b were satisfied on December 31, 1979.

This response was prepared by the licensee's corporate office based on site input and was concurred in by both corporate and site management.

2.

NRC Actions The NRC took escalated enforcement action in the 10/17/80 NRC Region

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forms of both a civil penalty and orders. A civil I letter penalty was assessed as a results of the false (IAL 80-40);

statement contained in the licensee's response 11/26/80 NRC letter to Show Cause. An Order for license modification, EA 81-08; effective immediately, was levied on the licensee 3/20/81 NRC letter by the NRC which required the removal of the li-3/25/81 Licensee censee's General Site Superintendent from involvement letter in nuclear matters. Additionally, a Show Cause Order was issued requiring the licensee to justify why a Corporate Vice-President also should not be so removed. Additionally, an IAL was. issued by NRC, Region I, to obtain licensee commitments to 7

gomply with the Item 2.1.8.b requirements, d

Based on further NRC investigation and an ex-tensive NRC review of the circumstancWsur-rounding this issue and the licensee's cor-rective action, the two orders wer.e subsequently lifted and the individual was reinstated as General Site Superintendent.

The civil penalty was mitigated and the licensee for-warded payment of $215,000.

The NRC cont ~inues to monitor the licensee's performance.

3.

Licensee Corrective Actions In IAL 80-40, the licensee committed to 10/17/80 NRC Region correct the technical problems associated I letter with the interim method for noble gas re-(IAL 80-40) lease measurement. The licensee established 1/3/81 Licensee procedures both at the site and at the letter corporate office designed to improve the IE Report 50-220/

management control of the information within 81-03 the licensee's organization.

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