ML20210P977
| ML20210P977 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/22/1997 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-11, 50-457-97-11, NUDOCS 9708270433 | |
| Download: ML20210P977 (4) | |
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Document Contaol Desk U S. Nuclear llegulatory Conunission I
Washington, D C 20555
Subject:
1(eply to Notice of Violation NilC inspection Report 50-456(457)/97011 liraidwood Nuclear Power Station Units I and 2 MitDmketMtmbertSMbixL5H12 Reference J A Urobe letter to 110 Stanley dated July 24.1997, transmitting Notice of Violation from inspection Report 50-456(457)/97011 The inspection report specified in the Referenc'c above includes results from an inspection ofliraidwood's solid radioactive waste processing and shipping program which ended on June 24,1997. A Notice of Violation was transmitted with the referenced report and included one Severity 1 evel IV Violation associated with procedure adherence. The attachment to this letter contains Comed's response to this violation Station Management has continued to emphasize the importance of procedure adherence during lluman Performance sessions Two lluman Performance sessions were conducted in 1997 and two additional sessions are scheduled to take place later in the year. In addition, a trending piogram on procedure adherence events has been established with classification on type of adherence issue. A team has been established at Bdiated to review a selected number of administrative procedures to determine if the instrrtions need to be clarified or ifincreased training is needed. The goal of this team is to e iprove administrative procedure compliance by clarifying the requirements to plant personnel, These actions are being taken to improve both the awareness of procedure adherence requirements and improve Station performance The following commitment was made in the attached response:
. e'{ g' llwRP 5600 6, " Scaling Factor Determination," is being reviewed and revisions will be e
made as necessary. In addition, the Station plans to enhance the procedure by adding an additional signature block for a secondary reviewer.
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9708270433 970822 PDR ADOCK 05000456 G
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'lhtettultnLCin11tul.DeskE2!91 Pagt2 If your stair has any questions or comments concerning this letter, please refer them to Terrence Simpkin, liraidwood Regulatory Assurance Supervisor, at (81$) 458 2801, extensiou 2980
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bene Stanley g
Site Vice President liraidwood Nuclear Generating Station lei 4.4*d191rd d.n Attachment cc:
A.ll Ileach, NRC Regional Administrator, Region 111 G F Dick, Jr., Project Manager, NRR l
C J. Phillips, Senior Resident inspector F Niziotek Division oflingineering, Ollice of b aclear Safety, IDNS G
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A1TACilMENT I 4
REPLY TO NOTICE OF VIOLATION bYJDL6 HON dn 4ML4$7W7uIl nt) 10 CFR 61.55(a)(8) requires, in part, that if the licensee determines the concentration of a radionuclide in wastes via indirect methods such as the use of scaling factors, the licensee provide reasonable assurance that the indirect method can be correlated with actual measurements.
Procedure llwRP $600 0, " Scaling Factor Determination," revision 0, was prepared by the licensee to ensure that indirect methods, i.e. scaling factors, can be correlated with actual sample measurements.
Step F 2 e of procedure 11wRP 5000 6 required that if any of the radionuclide scaling factors calculated Ibr an individual waste stream sample differed fiom the current scaling factor by a f actor of 10 or more, an additional sample of the waste sticam be sent to an off site laboratory for analysis.
Contrary to the above, the inspector identified that on August 12,1994, March 28, 1995, and June 5,1996, the licensee did not provide reasonal. e assurance that indirect methods could be correlated with action measurements. Specifically, the licensee did not re sample waste streams which differed fiom current scaling factors by a factor of ten or greater.
RIMSON EDILTJHLYJDIEUDN liwRP 5600 0," Scaling Factor Determination" Procedure, pertains to the analysis of radiological waste streams at Ilraidwood Station and is perfbrmed on an annual basis. The procedure, classilied as " Reference Use", is used to perform statistical analyses of waste stream samples Sample results that fall outside of a predctermined range are considered
" outliers " Step F 2 c. II in the procedure requires that these " outlier" samples be analyzed offsite During a recent inspection, no records could be found to show that the outlier samples had been sent olisite Ibr analysis as required in 1994,1995, and 1996. Personnel who performed 06vRP $600 6 during those years failed to complete the step in the procedure requiring this action. Although the individual responsible for performing the procedure in 1994 and 1995 is no longer a Comed employee, the individual was contacted to determine why he did not satisfy the procedure requirement, As the original author of the procedure, the individual assumed that he was aware of all of the procedure requirements Therefore, when the outliers were discovered, he did follow up with the offsite analysis vendor to discuss the results. The individual rationalized that the follow up actions taken were appropriate, however these actions did not satisfy the requirements stated in the procedule. The individual responsible ihr perfbrming the procedure in 1996 was also interviewed to determine why he did not adhere to the procedure. This individual i
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l ATTACllMIINT I I
Rlil'LY TO NOTICII Of VIOLATION
- VIOLATlQtWE4ML4171/970ll 01) conununicated that he reviewed the entire procedure prior to executing the steps as required ihr procedur(s classified as " Reference Use" While per forming the procedure, the individual was focused on complicated data analysis sections of the procedure, which were executed over a several day period, and through inattention to detail, he failed to satisfy the requirement to send additional samples olTsite for analysis as required for outlier sampl ;
CORRl!CTIVi! ACTl0N,LTAMiiN AND RESULTS ACilliiYliD The individual who performed the llwRP $000 6 in 1996 was counseled on procedme adherence expectations The Station pe fbimed a technical evaluation of the procedme adherence denciency.
liased on a review of the source document which was used as a refeience when the procedure was initially written and a discussion with the author of the source document, the Station concluded that the circumstances would have had no impact on waste classi0 cations ACTIONS TAKliN To pMiVi!NT RECUlmiiECli Ilraidwood Station has continued to reinforce expectations associated with procedure adherence during quarterly Human Performance sessions. These rueetings have served to heighten awareness levels of Station personnel of their responsibilities when ibliowing k
procedures The requirement of performing additional analyses of outlier samples is being reviewed and revisions will be made as necessary. In addition tc revising the outlier sampling requirement, the Station plans to enhance the procedure by adding an additional signature block for a secondary reviewer This change will provide additional assurance that the procedure was completed as required IMIli3niENfLALG1Ml11AN01.A' AliK11111YIiD Full compliance was achieved when the individual who failed to peribrm the procedure as required was counseled on procedure adherence expectations.
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