ML20082F680
| ML20082F680 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/03/1995 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP1L-0925, NMP1L-925, NUDOCS 9504120239 | |
| Download: ML20082F680 (4) | |
Text
_ - - _
M Y NIAGARA R UMOHAWK NIAGARA MOHAWK POWER CORPORATION /NINE MILE POINT, P.O. BOX 63, LYCOMING, NY 13093/ TELEPHONE (315) 349-2882
' B. Ralph SyMa Executive Vice President
- c '**' '
April 3,1995 NMP1L 0925 t
l l
[
U. S. Nuclear Regulatory Commission
['
Attr.: Document Control Desk i
Washington, DC 20555 RE: Nine Mile Point Unit 1 Docket No. 50-220 DPR-63
Subject:
Response to Notice of Violation - NRC Combined Inspection Report
(
$0-220/95M cad 50410/95-04 Gentlemen:
Attached is Niagara Mohawk Power Corporation's response to the Notice of Violation contained in the subject Inspection Report dated March 6,1995. 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, fh/half>
b B. Ralph Sylvia Executive Vice President - Nuclear BRS/RLM/Imc Attachment xc:
Mr. T. T. Martin, Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. L. B. Marsh, Director, Project Directorate I-1, NRR Mr. G. E. Edison, Senior Project Manager, NRR Records Management i
12001'7 9504120239 950403 PDR ADOCK 05000220 I
0 PDR
NIAGARA MOIIAWK POWER CORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR-63
" RESPONSE TO NOTICE OF VIOLATION," AS CONTAINED IN INSPECTION REPORT 50-220/95-04 AND 50-410/95-04 VIOLATION 50-220/95-04-01 During an NRC inspection conducted on February 27 - March 3,1995 a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below.
Title 10, Code of Federal Regulations, Part 20.1101(a), requires, in part, that licensees develop, document and implement a radiation protection program commensurate with the scope and extent of licensed activities.
Paragraph 3.7.4 of Procedure GAP-RPP-02, Rev. 3, " Radiation Work -
Permit," requires that personnel access the radiologically controlled area (RCA) using either a General, Standing or Specific radiation work permit E
(RWP). Paragraph 2.5 of this same procedure states that personnel are responsible for complying with the requirements of their RWP.
Paragraph 3.3.1 of Procedure GAP-RPP-07, Rev.1, " External Dosimetry Program," requires that personnel entering the RCA wear their whole body dosimetry, which includes electronic dosimeters or self-reading dosimeters (SRDs).
Contrary to the above, the licensee failed to properly implement the radiation protection program procedures, as evidenced by the following.
j On February 13,1995, a worker who entered the RCA failed to wear his electronic dosimeter or SRD.
On February 25,1995, a radiation worker who entered the RCA failed to sign in on an RWP and failed to wear an electronic dosimeter or SRD.
This is a Severity 12 vel IV violation (Supplement IV).
Page 1
(
w-7 I.
THE REASON FOR THE VIOLATION Niagara Mohawk concurs with the violation as stated in Inspection Report 50-220/95-04 and 50-410/95-04.
Two additional events occurred while preventive actions were being formulated for the two cited events: a worker entered the Radiologically Controlled Area (RCA) without his DD-100 electronic dosimeter; and a worker entered the RCA without having electronically logged on an RWP and without an activated DD-100 electronic dosimeter.
A root cause analysis was performed in accordance with Nuclear Interface Procedure NIP-ECA-01, " Deviation / Event Report." The root cause for all four events was determined to be poor work practices. Behavior factors analysis indicates that the involved personnel applied an insufficient degree of attention to RCA entry tasks. Involved personnel were distracted by other work activities when they entered the RCA.
H.
CORRECTIVE ACTIONS TAKRN AND RESUL1'S ACHIEVED The above described incidents have been self-identified. Deviation / Event Reports were initiated for each incident to document causes and corrective / preventive actions. The corrective actions included:
1.
Individuals involved in the specific incidents have been coached and counseled on the importance of maintaining focus on the tasks at hand, proper dosimetry monitoring and adherence to Radiation Protection Program requirements.
2.
For the remainder of Refuel Outage 13, full time dedicated personnel are established at the RCA entrance to ensure that personnel have an activated DD-100 electronic dosimeter prior to entering the RCA.
111.
ACTIONS TAKEN TO PREVENT RECURRENCE The following long term preventive actions are being taken to address this event.
1.
The incidents have been reviewed with the remainder of the work force during
" tailgate" meetings held with individual work groups. During these meetings emphasis was placed on staying focused on radiation protection requirements upon entering and working in the RCA.
2.
Industry benchmarking is being performed to determine other methods available to minimize these types of errors. Preliminary results indicate that most other utilities have experienced similar problems. Varied corrective actions have been taken but there appears to be no single definitive preventive action. NMPC will evaluate the results and implement additional corrective measures as appropriate.
Page 2
J
.('
JY.
DATE WUEN FULL COMPLEANCE WILL BE ACHIEVED Full compliance with the requirements of Radiation Protection Program procedures and 10 CFR Part 20 was reestablished immediately following each incident with the removal of the individuals from the RCA.
1 1
Page 3 l
i
-