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| number = ML17264A872
| number = ML17264A872
| issue date = 04/29/1997
| issue date = 04/29/1997
| title = Responds to NRC 970325 Ltr Re Violations Noted in Insp Rept 50-244/97-01 on 970105-970223.Corrective Actions:Held Meetings on 970211-12 W/Available Members of Nuclear Operations Group to Discuss Radiological Work Practices
| title = Responds to NRC Re Violations Noted in Insp Rept 50-244/97-01 on 970105-970223.Corrective Actions:Held Meetings on 970211-12 W/Available Members of Nuclear Operations Group to Discuss Radiological Work Practices
| author name = Mecredy R
| author name = Mecredy R
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = 50-244-97-01, 50-244-97-1, NUDOCS 9705070042
| document report number = 50-244-97-01, 50-244-97-1, NUDOCS 9705070042
| title reference date = 03-25-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 22
| page count = 22
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=Text=
=Text=
{{#Wiki_filter:JAN-11-1988       87: 14         U.S. NRC GINNA                                   315 524 6937                           P.82 AND ROQIESItR 64S AhQElFCTRIC CORPORAIION ~ 8P FASTAVEMIFROCIIESIER,PI Y. MiQP4%1     ARFA OAF''/6666 2250 808ERT C. ME CREDY Vice lresdenl Nvdcer   operol~
{{#Wiki_filter:JAN-11-1988 87: 14 U.S.
April 29, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn:           Guy S. Vissing Project Directorate I-l Washington, D.C. 20555
NRC GINNA 315 524 6937 P.82 AND ROQIESItR 64S AhQElFCTRIC CORPORAIION ~ 8P FASTAVEMIFROCIIESIER,PI Y. MiQP4%1 ARFAOAF''/6666 2250 808ERT C. MECREDY Vice lresdenl Nvdcer operol~
U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I-l Washington, D.C. 20555 April29, 1997


==Subject:==
==Subject:==
Line 23: Line 26:


==Dear Mr. Vissing:==
==Dear Mr. Vissing:==
Rochester Gas and Electric (RG&E) provides this reply to the Notice of Violation (VIO 50-244/97-01-02) submitted as an enclosure to a leer from Lawrence T. Doerflein, USNRC, to Robert C. Mecredy, RG&E, dated March 25, 1997.
As a result of an inspection conducted from January 5 to February 23, 1997, the following violation of NRC requirements was identified. In accordance with the Enforcement Policy (NUREG-1600), the violation is listed'elow:
"10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures be established to assure that conditions adverse to quality, such as.deficicncies and deviations are promptly identified and corrected.
Contrary'to the above, the licensee failed to correct problems regarding contamination
'oundary control and poor radiological work practices noted in NRC Inspection Report Nos.
50-244/94-29 and 50-244/96-11, and RG&E ACTION Report No. 96-0902 dated September 27, 1996, as evidenced by the following:
February 9, 1997, maintenance tools were removed from a designated contamination area on the A-Safety Injection pump.
Several rags and a wire brush that had been used inside an area with loose smearable surface contamination were allowed to straddle across the boundary marker line and extend into an uncontaminated area.
These items were not surveyed prior to being removed from the contaminated area.
Other wrenches and tools that had been used inside a contaminated area were removed and placed on a clean surface without having been bagged or surveyed for contamination beforehand.


Rochester Gas and Electric (RG&E) provides this reply to the Notice of Violation (VIO 50-244/97-01-02) submitted as an enclosure to a leer from Lawrence T. Doerflein, USNRC, to Robert C. Mecredy, RG&E, dated March 25, 1997. As a result of an inspection conducted from January 5 to February 23, 1997, the following violation of NRC requirements was identified. In accordance with the Enforcement Policy (NUREG-1600), the violation is listed'elow:
JAN-11-1988 87: 14 U. S.
            "10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures be established to assure that conditions adverse to quality, such as.deficicncies and                    .
NRC GINNA 315 524 6937 P. 83 Page 2 2)
deviations are promptly identified and corrected.
February 17, 1997, a leak from a fitting on the transmitter of a flow instrument (FI-116) was dripping from inside a contaminated area onto a clean fioor surface that was designated as uncontaminated.
Contrary'to the above, the licensee failed to correct problems regarding contamination control and poor radiological work practices noted in NRC Inspection Report Nos.
A towel had been placed on the fioor was collecting the leakage (sic), but the towel was saturated with the radioactive fiuid. Vfater was fiowing away from the towel to a low point in the floor, forming a puddle, and contaminating previously clean fioor areas up to 2700 dpm/100cm'.
                                                                                                      'oundary 50-244/94-29 and 50-244/96-11, and RG&E ACTION Report No. 96-0902 dated September 27, 1996, as evidenced by the following:
No coHecuoa device was in place that could prevent the spread of contaminated water to uncontaminated areas.
February 9, 1997, maintenance tools were removed from a designated contamination area on the A-Safety Injection pump. Several rags and a wire brush that had been used inside an area with loose smearable surface contamination were allowed to straddle across the boundary marker line and extend into an uncontaminated area. These items were not surveyed prior to being removed from the contaminated area. Other wrenches and tools that had been used inside a contaminated area were removed and placed on a clean surface without having been bagged or surveyed for contamination beforehand.
The radiological protection technician on duty at the time was aot aware of this condition.
 
BACKGROUND 1.
315 524 6937            P. 83 JAN-11-1988   87: 14       U. S. NRC GINNA Page 2
Inspection Report 94-29 NRC Inspection Report 94-29 dealt with review of accessible areas of the plant to verify that high radiation doors were locked, and radiological postings were posted as required.
: 2)         February 17, 1997, a leak from a fitting on the transmitter of a flow instrument (FI-116) was dripping from inside a contaminated area onto a clean fioor surface that was designated as uncontaminated. A towel had been placed on the fioor was collecting the leakage (sic), but the towel was saturated with the radioactive fiuid. Vfater was fiowing away from the towel to a low point in the floor, forming a puddle, and contaminating previously clean fioor areas up to 2700 dpm/100cm'. No coHecuoa device was in place that could prevent the spread of contaminated water to uncontaminated areas. The radiological protection technician on duty at the time was aot aware of this condition.
Some variability in the use of contamination bouadary demarcation tape (rad tape) was noted.
BACKGROUND
In some areas, rad tape was used on the fioor to define the contamination area boundary marker line, and in other areas this was not used.
: 1. Inspection Report 94-29 NRC Inspection Report 94-29 dealt with review of accessible areas of the plant to verify that high radiation doors were locked, and radiological postings were posted as required. Some variability in the use of contamination bouadary demarcation tape (rad tape) was noted. In some areas, rad tape was used on the fioor to define the contamination area boundary marker line, and in other areas this was not used. For example, for one area a contamination rope barricade and posting were used without a floor rad tape boundary marker line.
For example, for one area a contamination rope barricade and posting were used without a floor rad tape boundary marker line.
The inspector also noted an extension cord and a hose running from a clean gaea into a, contaminated area without a clear   definition of the clean or contaminated portion of the cord and hose. Both the cord and hose had been pulled loose during the work evolution and the original position of the cord and hose could not be determined. RGErE reestablished a clear contamination boundary marker line and stated that the use of rad tape would be reevaluated.
The inspector also noted an extension cord and a hose running from a clean gaea into a, contaminated area without a clear definition of the clean or contaminated portion of the cord and hose.
NRC Inspection Report 96-11 As reported in NRC Inspection Report 96-11, NRC inspectors observed a work area with some work partially conducted inside a roped-off contamination area. The inspector noted that several equipment service lines and power cords were not secured within thc contamination area. Significant amounts of tape, grinding dust, and miscellaneous debris generated from welding and grinding work had Mea to the floor and were accumulating outside the contamination area boundary. The step-off pad for exiting the contamination area was not securely attached to the floor. Several buckets that
Both the cord and hose had been pulled loose during the work evolution and the original position of the cord and hose could not be determined.
RGErE reestablished a clear contamination boundary marker line and stated that the use of rad tape would be reevaluated.
NRC Inspection Report 96-11 As reported in NRC Inspection Report 96-11, NRC inspectors observed a
work area with some work partially conducted inside a roped-off contamination area.
The inspector noted that several equipment service lines and power cords were not secured within thc contamination area.
Significant amounts of tape, grinding dust, and miscellaneous debris generated from welding and grinding work had Mea to the floor and were accumulating outside the contamination area boundary.
The step-off pad for exiting the contamination area was not securely attached to the floor. Several buckets that


Page 3 were used to collect contaminated fluids were not labeled properly.
Page 3 were used to collect contaminated fluids were not labeled properly.
NRC inspector also noted additional contanunation boundary control concerns, where loose bags and papers within the contamination area were allowed to collect on the floor and extend across the boundary marker line. Cords and test leads were not secured to thc fioor to prevent them from canying contamination out of the area.
NRC inspector also noted additional contanunation boundary control concerns, where loose bags and papers within the contamination area were allowed to collect on the floor and extend across the boundary marker line.
When notified by the NRC inspector of this condition, RG&E personnel immediately cleaned up the debris in and outside of the contamination area and secured the service lines to the floor to prevent thein from being moved across the boundary marker line. Radiological surveys were taken and no spread of contamination was detected. However, RG&E agreed that management expectations for proper contamination boundary controls had not been met.
Cords and test leads were not secured to thc fioor to prevent them from canying contamination out of the area.
When notified by the NRC inspector of this condition, RG&E personnel immediately cleaned up the debris in and outside of the contamination area and secured the service lines to the floor to prevent thein from being moved across the boundary marker line. Radiological surveys were taken and no spread of contamination was detected.
However, RG&E agreed that management expectations for proper contamination boundary controls had not been met.
Site personnel working in these areas were subsequently counseled.
Site personnel working in these areas were subsequently counseled.
3.'CTION Report 964902 ACTION Report 96-0902 dealt with contaminated tools/equipment found in unrestricted area tool storage areas. These tools were found as a result of the annual Radiation Protection (RP) surveys of these areas.
3.'CTION Report 964902 ACTION Report 96-0902 dealt with contaminated tools/equipment found in unrestricted area tool storage areas.
(1) The reasons for the violation, or,     if contested, the basis for disputing the violation; RG&E accepts the violation. We agree that problems regarding contamination boundary control*and poor radiological work practices have not been programmatically corrected.
These tools were found as a result of the annual Radiation Protection (RP) surveys of these areas.
(a)     Safety Injection Pump The area around the safety injections pumps is very congested. Contaminated surface area boundaries are denoted by rad tape. The initial work planned for the area was to inspect and, if necessary, tighten some leaking Swagelok fittings. Typically, the small contamination control area established for this work scope is adequate.
(1)
Based on inspection   of the leaking fittings, the work scope was expanded to include tubing replacement. Discussions occurred between the workers and Radiation Protection (RP) technician relative to the expanded work scope, but there was no decision to enlarge the contamnation control area boundary to better optimize the work environment. Enlarging the work area would have better accouunodated the expanded work scope and eliminated the need to
The reasons for the violation, or, ifcontested, the basis for disputing the violation; RG&E accepts the violation. We agree that problems regarding contamination boundary control*and poor radiological work practices have not been programmatically corrected.
(a)
Safety Injection Pump The area around the safety injections pumps is very congested.
Contaminated surface area boundaries are denoted by rad tape.
The initial work planned for the area was to inspect and, ifnecessary, tighten some leaking Swagelok fittings. Typically, the small contamination control area established for this work scope is adequate.
Based on inspection of the leaking fittings, the work scope was expanded to include tubing replacement.
Discussions occurred between the workers and Radiation Protection (RP) technician relative to the expanded work scope, but there was no decision to enlarge the contamnation control area boundary to better optimize the work environment.
Enlarging the work area would have better accouunodated the expanded work scope and eliminated the need to


JAN-11-1988 87: 16       U.S. NRC GINNA                                     315 524 6937               P.85 Page 4 transfer hand tools and other items in and out of the contaminated area that had previously been established. There was a lack of alertness on the part of the workers and RP technician that the contamination area boundary should have been enlarged for more effective contamination control.
JAN-11-1988 87: 16 U.S.
NRC GINNA 315 524 6937 P.85 Page 4 transfer hand tools and other items in and out of the contaminated area that had previously been established.
There was a lack of alertness on the part of the workers and RP technician that the contamination area boundary should have been enlarged for more effective contamination control.
The tool removed from the contaminated area was used to tighten a Swagelok nut that had been previously smeared and was free of loose contamination.
The tool removed from the contaminated area was used to tighten a Swagelok nut that had been previously smeared and was free of loose contamination.
Athough full compliance to contaminated area boundary control was lacking, smearing the nut was a positive step which is representative of ongoing efforts at the work area to help minimize the spread of contamination. The rags, wire brush, and wrench should have been bagged prior to removal from the contaminated area.
Athough full compliance to contaminated area boundary control was lacking, smearing the nut was a positive step which is representative of ongoing efforts at the work area to help minimize the spread of contamination.
A contributing factor was the small contaminated area boundary. An enlarged boundary would have eliminated the need to transfer these items in and out of the contaminated area. Thus, bagging prior to final removal would have been accomplished as a standard, acceptable work practice, if the contaminated area had been properly enlarged.
The rags, wire brush, and wrench should have been bagged prior to removal from the contaminated area.
(b) Leak from How Transmitter FI-116 It is not known   who placed the absorbent towel under the transmitter, nor how long the towel had been there before the NRC inspector identified the problem, RG&E acknowledges that an absorbent towel is not an appropriate method for containing contaminated liquid. This is an unacceptable work practice. A catch containment or bucket should have been used.
A contributing factor was the small contaminated area boundary.
An enlarged boundary would have eliminated the need to transfer these items in and out of the contaminated area.
Thus, bagging prior to final removal would have been accomplished as a standard, acceptable work practice, ifthe contaminated area had been properly enlarged.
(b)
Leak from How Transmitter FI-116 It is not known who placed the absorbent towel under the transmitter, nor how long the towel had been there before the NRC inspector identified the
: problem, RG&E acknowledges that an absorbent towel is not an appropriate method for containing contaminated liquid. This is an unacceptable work practice.
A catch containment or bucket should have been used.
As background for how this situation developed, a Maintenance Work Order had previously identified a boron buildup on a Swagelok fitting to Pl-116.
As background for how this situation developed, a Maintenance Work Order had previously identified a boron buildup on a Swagelok fitting to Pl-116.
This prompted RP to provide contamination boundary controls to the immediate area adjacent to Fl-116. Initially described as a dry boron buildup, leak progressed to thc point of a steady drip. It could not be ascertained at
This prompted RP to provide contamination boundary controls to the immediate area adjacent to Fl-116. Initiallydescribed as a dry boron buildup,
                                                                                                        'he what stage in leak development the absorbent towel was placed under the transmitter.
'he leak progressed to thc point of a steady drip. It could not be ascertained at what stage in leak development the absorbent towel was placed under the transmitter.
(c) Contaminated Area Boundary Control RG&E acknowledges that corrective actions for previously identified poor radiological work practices and inadequate contamination boundary controls were not effective. There have been additional incidents in these areas. The programmatic requirements need to be strongly reinforced. These incidents are the result of lapses in performance and failure to adhere to the established management expectations and standards.
(c)
Contaminated Area Boundary Control RG&E acknowledges that corrective actions for previously identified poor radiological work practices and inadequate contamination boundary controls were not effective.
There have been additional incidents in these areas.
The programmatic requirements need to be strongly reinforced.
These incidents are the result of lapses in performance and failure to adhere to the established management expectations and standards.


315 524 6937                P. 86 JAN-11-1988 87: 17     U. S. NRC GINNA Page 5 Therefore, as discussed in detail under corrective actions the focus wl'0 be 011
JAN-11-1988 87: 17 U. S.
                        'n clear and unambiguous expectations for boundary demarcat' ious an control, additional mana management e      coaching and counscliag, heightened awareness         of thcse ness 0 anced training, enforcing consistency in application of standards, reinforcement of individual accountability and responsibility, and monitoring to ensure continuing compliance.
NRC GINNA 315 524 6937 P. 86 Page 5 clear and Therefore, as discussed in detail under corrective actions the fo
'0 be cus wl 011 additional mana e
and unambiguous expectations for boundary demarcat'ious an
: control,
'n management coaching and counscliag, heightened awareness of th anced training, enforcing consistency in application of ness 0 cse standards, reinforcement of individual accountability and responsibility, and monitoring to ensure continuing compliance.
The corrective steps that have been taken and the results achieved:
The corrective steps that have been taken and the results achieved:
(a)       On February 11/12, 1997, meetings were held with all available members of the Nuclear Operations Group. These meetings provided an opportunity for the Plant Manager to discuss radiological work im practices and contamination boundary control. The importaace             of crence to procedures and the seriousness of lapses in acceptable aadherence practices coacerniag contamination boundary control was personally conveyed by plant management.
(a)
(b}     At the request of'aintenance Supervision the Ginn       irma Stat'tion rmcr pal ysicist mct   with members of appropriate shops to outline concerns with improper contamination boundary control and to review station requirements and management expectations. Separate meetings were held with each of the followiag shops:
On February 11/12, 1997, meetings were held with all available members of the Nuclear Operations Group.
These meetings provided an opportunity for the Plant Manager to discuss radiological work adherence to practices and contamination boundary control.
The im importaace of a
crence to procedures and the seriousness of lapses in acceptable practices coacerniag contamination boundary control was personally conveyed by plant management.
(b}
At the request of'aintenance Supervision the Ginn Stat' irma tion rmcrpal ysicist mct with members of appropriate shops to outline concerns with improper contamination boundary control and to review station requirements and management expectations.
Separate meetings were held with each of the followiag shops:
Mechanical Maintenance Electrical Maintenance Instrument and Control (E&C)
Mechanical Maintenance Electrical Maintenance Instrument and Control (E&C)
I&C Special Projects.
I&C Special Projects.
(c)     A letter   was issued by the Plant Manager'nd Superintend ts t all p       personnel,   dated March 20, 1997, regarding management expectations for contamination boundary control. Thiis Ietter em hasized emp             tha all personnel are accountable for obeying established size that radiological boundaries when entering the restricted ri     area. . It further em p hasized as     tthat if instructions are not clear or fully understood th en the planned work should not be initiated, and that it is the worker's responsibi ity to ensure that all instructions are understood. The letter further stated that any incident of unacceptable radiological work practice will result in a meeting with supervisiou, and further disciplinary action may=be necessary.
(c)
A letter was issued by the Plant Manager'nd Superintend ts t all p
personnel, dated March 20, 1997, regarding management em hasized tha expectations for contamination boundary control. Thi I is etter emp size that all personnel are accountable for obeying established radiological boundaries when entering the restricted
. I furth em hasized t ri area.
t er the p as that ifinstructions are not clear or fullyunderstood th planned work should not be initiated, and that it is the worker's en responsibi ity to ensure that all instructions are understood.
The letter further stated that any incident of unacceptable radiological work practice willresult in a meeting with supervisiou, and further disciplinary action may=be necessary.


315 524 6937            P. 87 87: 17         U.S. NRC GINNA JAN-11-1988 Page 6 (3)   The corrective steps that will be taken to avoid further violations.
JAN-11-1988 87: 17 U.S.
NRC GINNA 315 524 6937 P. 87 Page 6 (3)
The corrective steps that willbe taken to avoid further violations.
The Radiation Protection (RP) Group has been assigned responsibility to coordinate implemention of all corrective actions discussed below.
The Radiation Protection (RP) Group has been assigned responsibility to coordinate implemention of all corrective actions discussed below.
()
( )
(a)      rocedures will be reviewed, and revised as appropriate, to provide Procedur clear and unambiguous management direction. Any changes will clearly state acceptable practices for contamination boundary control.
rocedures willbe reviewed, and revised as appropriate, to provide (a)
In addition, any changes will include clear definitions of the various types of acceptable contamination boundary markers.
Procedur clear and unambiguous management direction.
(b)     Contamination boundary control issues will be discussed at regularly scheduled shop meetings by Maintenance Supervision, to reinforce its
Any changes will clearly state acceptable practices for contamination boundary control.
                                                                                              'd importance. Periodically, RP personnel will be requested to attend these meetings to provide clarification and foster increased communications between groups.
In addition, any changes willinclude clear definitions of the various types of acceptable contamination boundary markers.
(c)     RP Supervision has directed the RP staff and RP techni strong coaching to radiological workers. This is being done to ensure personnel are effective in assisting workers in maintaining e ffective
(b)
                                                'P mination boundary control. Vfhen practicable, assigned RP contamina personnel arc expected to be iu the work area when work activites are occurring within contaminated areas, to ensure management expectations are being met.
Contamination boundary control issues willbe discussed at regularly scheduled shop meetings by Maintenance Supervision, to reinforce its importance.
(d)        raining Work Requests have been initiated to provide enhanced Tra'raining in contaminated area situations.
Periodically, RP personnel willbe requested to attend these meetings to provide clarification and foster increased communications between groups.
(e)     A Root     Cause Analysis is being performed to identify other factors that have contributed to poor radiological work practices in the past.
(c)
Corrective actions, if needed, will address these factors, to assist in eve oping other appropriate means to strengthen the programmatic requirements and to increase compliance with these requirements.
RP Supervision has directed the RP staff and RP techni'd strong coaching to radiological workers.
                                'As a   joint effort between Maintenance, RP, and Nuclear Training, "Project Boundary" has been established. Major attributes of this project include:
This is being done to ensure contamina
'P personnel are effective in assisting workers in maintaining ff e ective mination boundary control.
Vfhen practicable, assigned RP personnel arc expected to be iu the work area when work activites are occurring within contaminated areas, to ensure management expectations are being met.
raining Work Requests have been initiated to provide enhanced (d)
Tra'raining in contaminated area situations.
(e)
A Root Cause Analysis is being performed to identify other factors that have contributed to poor radiological work practices in the past.
Corrective actions, ifneeded, willaddress these factors, to assist in eve oping other appropriate means to strengthen the programmatic requirements and to increase compliance with these requirements.
'As a joint effort between Maintenance, RP, and Nuclear Training, "Project Boundary" has been established.
Major attributes of this project include:
Communication of management expectations Boundary Control policies that are easy to use Training for ALLgroups oa revisions to boundary control policies
Communication of management expectations Boundary Control policies that are easy to use Training for ALLgroups oa revisions to boundary control policies


315 524 6937            P. 88 JAN-11-1988   87: 18       U.S. HRC GthNA Page 7 Reinforcing and rewarding good behaviors Revising Training programs Train contractors (who work during outages) to the same level as RGB workers Verify adequacy of these actions against predetermined indicators (g)     An independent effectiveness Review wiH be conducted to verify the adequacy of the above listed corrective actions. This review willbe completed by October, 1997.
JAN-11-1988 87: 18 U.S.
C (4)   The date when full compliance will be achieved:
HRC GthNA 315 524 6937 P. 88 Page 7 Reinforcing and rewarding good behaviors Revising Training programs Train contractors (who work during outages) to the same level as RGB workers Verifyadequacy ofthese actions against predetermined indicators (g)
Pull compliance has been achieved as of March 20, 1997, when short term corrective actions, including heightened awareness and restatement of management expectations, were completed. Purther long term enhancements, as discussed in corrective actions (a) through (g) above, willresult in a more effective program.
An independent effectiveness Review wiHbe conducted to verifythe adequacy ofthe above listed corrective actions.
Very     y yours, Robert C. Mecredy xc:   Guy S. Vissing (Mail Stop 14C7)
This review willbe completed by October, 1997.
Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19046 Ginna Senior Resident Inspector TOTAL P.88
C (4)
The date when fullcompliance willbe achieved:
Pull compliance has been achieved as ofMarch 20, 1997, when short term corrective actions, including heightened awareness and restatement ofmanagement expectations, were completed.
Purther long term enhancements, as discussed in corrective actions (a) through (g) above, willresult in a more effective program.
Very y yours, Robert C. Mecredy xc:
Guy S. Vissing (Mail Stop 14C7)
Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19046 Ginna Senior Resident Inspector TOTAL P.88


1 CATEGORY 1           .
CATEGORY
REGULATORY INFORMATION DISTRIBUTION SYSTEM                 ( RI DS )
. 1 1
Iy ACCESSION NBR: 970507004 2               DOC . DATE: 97/04/29     NOTARIZED: NO                 DOCKET FACIL: 50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester                             G 05000244 AUTH NAME
REGULATORY INFORMATION DISTRIBUTION SYSTEM
            ~                      AUTHOR AFFILIATION ECREDY, R C ~~            Rochester Gas & Electric Corp.
( RIDS )
RECIP NAME
Iy ACCESSION NBR: 970507004 2 DOC. DATE: 97/04/29 NOTARIZED:
              ~                     RECIPIENT AFFILIATION VISSING   F G ~
NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH ~ NAME AUTHOR AFFILIATION ECREDY, R ~ C ~
Rochester Gas
& Electric Corp.
RECIP
~ NAME RECIPIENT AFFILIATION VISSING F G ~


==SUBJECT:==
==SUBJECT:==
Responds             to NRC 970325 1 t r re violations         noted in insp rept 50-244/97-0 1 on 970 1 05-970223 Corrective               actions: held meetings on 9702 1        l-l to discuss
Responds to NRC 970325 1tr re violations noted in insp rept 50-244/97-0 1 on 970 1 05-970223
                                                            ~
~ Corrective actions: held meetings on 9702 1l-l2 w/avai lable members of Nuclear Operations Group to discuss radiological work practices
2 w/avai lable members radiological of Nuclear work practices Operations        Group                                                        ~
~
DISTRIBUTION CODE: IE01D TITLE: General             50 COPIES RECEIVED:LTR Dkt ) -Insp Rept/Notice of 3
DISTRIBUTION CODE:
Violation ENCL Q    SIZE:
IE01D COPIES RECEIVED:LTR 3 ENCL Q SIZE:
TITLE: General
( 50 Dkt ) -Insp Rept/Notice of Violation Response NOTES: License Exp date in accordance with 1 OCFR2, 2. 109 ( 9/19/72 )
05000244 RECIPIENT ID CODE/NAME PD1-1 PD INTERNAL: AEOD/SPD/RAB DEDRO NRR/DISP/P IPB NRR/DRPM/PECB NUD0 C S-ABS TRACT OGC/HDS 3 ERNAL: LITCO BRYCE, J H
NRC PDR COPIES LTTR ENCL RECIPIENT ID CODE/NAME VISSING, G ~
AEOD TTC
~F CE TE~
NRR/DRCH/HHFB NRR/DRPM/PERB OE DIR RGN1 FILE 01 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL NOTE TO ALL "RIDS" RECIPZENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROI DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 18 ENCL R'


===Response===
AND y
(
ROCHESTER GAS ANDElECTRIC CORPORATIOhf
NOTES:  License Exp date in accordance              with  1 OCFR2, 2 . 109  ( 9/19/72  )      05000244 RECIPIENT              COPIES            RECIPIENT                COPIES ID  CODE/NAME            LTTR ENCL        ID  CODE/NAME          LTTR ENCL PD1-1 PD                                    VISSING, G    ~
~ 89EASTAVENU~ RO HESTER, Ar.Y Idod9.cr'C
INTERNAL: AEOD/SPD/RAB                                    AEOD TTC DEDRO                                    ~FNRR/DRCH/HHFB CE  TE~
'PEA COD! 7ID5I52.'K ROB"RT C. NtECREDY Vice President Nvcfeor operations April29, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
I NRR/D SP/P PB    I NRR/DRPM/PECB                              NRR/DRPM/PERB NU D 0 C S AB S T RAC T                    OE  DIR OGC/HDS 3                                  RGN1      FILE    01 ERNAL: L ITCO BRYCE, J H                              NOAC NRC PDR                                    NUDOCS FULLTEXT NOTE TO ALL "RIDS" RECIPZENTS:
Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROI DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR                    18    ENCL      R'
 
AND y   ROCHESTER GAS AND ElECTRIC CORPORATIOhf ~ 89EASTAVENU~ RO HESTER, Ar.Y Idod9.cr'C 'PEA COD! 7ID5I52.'K ROB" RT C. NtECREDY Vice President Nvcfeor operations April 29, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn:           Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555


==Subject:==
==Subject:==
Line 114: Line 198:


==Dear Mr. Vissing:==
==Dear Mr. Vissing:==
 
Rochester Gas and Electric (RG&E) provides this reply to the Notice of Violation (VIO 50-244/97-01-02) submitted as an enclosure to a letter from Lawrence T. Doerflein, USNRC, to Robert C. Mecredy, RG&E, dated March 25, 1997.
Rochester Gas and Electric (RG&E) provides this reply to the Notice of Violation (VIO 50-244/97-01-02) submitted as an enclosure to a letter from Lawrence T. Doerflein, USNRC, to Robert C. Mecredy, RG&E, dated March 25, 1997. As a result of an inspection conducted from January 5 to February 23, 1997, the following violation of NRC requirements was identified. In accordance with the Enforcement Policy (NUREG-1600), the violation is listed below:
As a result of an inspection conducted from January 5 to February 23, 1997, the following violation of NRC requirements was identified. In accordance with the Enforcement Policy (NUREG-1600), the violation is listed below:
        "10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures be established to assure that conditions adverse to quality, such as deficiencies and deviations are promptly identified and corrected.
"10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures be established to assure that conditions adverse to quality, such as deficiencies and deviations are promptly identified and corrected.
Contrary to the above, the licensee failed to correct problems regarding contamination boundary control and poor radiological work practices noted in NRC Inspection Report Nos.
Contrary to the above, the licensee failed to correct problems regarding contamination boundary control and poor radiological work practices noted in NRC Inspection Report Nos.
50-244/94-29 and 50-244/96-11, and RG&E ACTION Report No. 96-0902 dated September 27, 1996, as evidenced by the following:
50-244/94-29 and 50-244/96-11, and RG&E ACTION Report No. 96-0902 dated September 27, 1996, as evidenced by the following:
February 9, 1997, maintenance tools were removed from a designated contamination area on the A-Safety Injection pump. Several rags and a wire brush that had been used inside an area with loose smearable surface contamination were allowed to straddle across the boundary marker line and extend into an-uncontaminated area. These items were not surveyed prior to being removed from the contaminated area. Other wrenches and tools that had been used inside a contaminated area were removed and placed on a clean surface without having been bagged or surveyed for contamination beforehand.
February 9, 1997, maintenance tools were removed from a designated contamination area on the A-Safety Injection pump.
9705070042 970429 PDR         ADOCK 05000244                                                   lllllll 8                         PDR                         g[llllllllllllllllllllltll
Several rags and a wire brush that had been used inside an area with loose smearable surface contamination were allowed to straddle across the boundary marker line and extend into an-uncontaminated area.
These items were not surveyed prior to being removed from the contaminated area.
Other wrenches and tools that had been used inside a contaminated area were removed and placed on a clean surface without having been bagged or surveyed for contamination beforehand.
9705070042 970429 PDR ADOCK 05000244 8
PDR g[llllllllllllllllllllltll lllllll


Page 2
Page 2 2)
: 2)     February 17, 1997, a leak from a fitting on the transmitter of a flow instrument (FI-116) was dripping from inside a contaminated area onto a clean; floor surface that was designated as uncontaminated. A towel had been placed on the floor was collecting the leakage (sic), but the towel was saturated with the radioactive fluid. Water was flowing away from the towel to a low point in the floor, forming a puddle, and contaminating previously clean floor areas up to 2700 dpm/100cm'. No collection device was in place that could prevent the spread of contaminated water to uncontaminated areas. The radiological protection technician on duty at the time was not aware of this condition.
February 17, 1997, a leak from a fitting on the transmitter of a flow instrument (FI-116) was dripping from inside a contaminated area onto a clean; floor surface that was designated as uncontaminated.
BACKGROUND Inspection Report 94-29 NRC Inspection Report 94-29 dealt with review of accessible areas of the plant to verify that high radiation doors were locked, and radiological postings were posted as required. Some variability in the use of contamination boundary demarcation tape (rad tape) was noted. In some areas, rad tape was used on the floor to define the contamination area boundary marker line, and in other areas this'was not used. For example, for one area a contamination rope barricade and posting were used without a floor rad tape boundary marker line.
A towel had been placed on the floor was collecting the leakage (sic), but the towel was saturated with the radioactive fluid. Water was flowing away from the towel to a low point in the floor, forming a puddle, and contaminating previously clean floor areas up to 2700 dpm/100cm'.
The inspector also noted an extension cord and a hose running from a clean area into a contaminated area without a clear definition of the clean or contaminated portion of the cord and hose. Both the cord and hose had been pulled loose during the work evolution and the original position of the cord and hose could not be determined. RG&E reestablished a clear contamination boundary marker line and stated that the use of rad tape would be reevaluated.
No collection device was in place that could prevent the spread of contaminated water to uncontaminated areas.
: 2. NRC Inspection Report 96-11 As reported in NRC Inspection Report 96-11, NRC inspectors observed a work area with some work partially conducted inside a roped-off contamination area. The inspector noted that several equipment service lines and power cords were not secured within the contamination area. Significant amounts of tape, grinding dust, and miscellaneous debris generated from welding and grinding work had fallen to the floor and were accumulating outside the contamination area boundary. The step-off pad for exiting the contamination area was not securely attached to the floor. Several buckets that
The radiological protection technician on duty at the time was not aware of this condition.
BACKGROUND Inspection Report 94-29 NRC Inspection Report 94-29 dealt with review of accessible areas of the plant to verify that high radiation doors were locked, and radiological postings were posted as required.
Some variability in the use of contamination boundary demarcation tape (rad tape) was noted.
In some areas, rad tape was used on the floor to define the contamination area boundary marker line, and in other areas this'was not used.
For example, for one area a contamination rope barricade and posting were used without a floor rad tape boundary marker line.
The inspector also noted an extension cord and a hose running from a clean area into a contaminated area without a clear definition of the clean or contaminated portion of the cord and hose.
Both the cord and hose had been pulled loose during the work evolution and the original position of the cord and hose could not be determined.
RG&E reestablished a clear contamination boundary marker line and stated that the use of rad tape would be reevaluated.
2.
NRC Inspection Report 96-11 As reported in NRC Inspection Report 96-11, NRC inspectors observed a
work area with some work partially conducted inside a roped-off contamination area.
The inspector noted that several equipment service lines and power cords were not secured within the contamination area.
Significant amounts of tape, grinding dust, and miscellaneous debris generated from welding and grinding work had fallen to the floor and were accumulating outside the contamination area boundary.
The step-off pad for exiting the contamination area was not securely attached to the floor.
Several buckets that


Page 3 were used to collect contaminated fluids were not labeled properly.
Page 3 were used to collect contaminated fluids were not labeled properly.
NRC inspector also noted additional contamination boundary control concerns, where loose bags and papers within the contamination area were allowed to collect on the floor and extend across the boundary marker line. Cords and test leads were not secured to the floor to prevent them from carrying contamination out of the area.
NRC inspector also noted additional contamination boundary control concerns, where loose bags and papers within the contamination area were allowed to collect on the floor and extend across the boundary marker line.
When notified by the NRC inspector of this condition, RG&E personnel immediately cleaned up the debris in and outside of the contamination area and secured the service lines to the floor to prevent them from being moved across the boundary marker line. Radiological surveys were taken and no spread of contamination was detected. However, RG&E agreed that management expectations for proper contamination boundary controls had not been met.
Cords and test leads were not secured to the floor to prevent them from carrying contamination out of the area.
When notified by the NRC inspector of this condition, RG&E personnel immediately cleaned up the debris in and outside of the contamination area and secured the service lines to the floor to prevent them from being moved across the boundary marker line.
Radiological surveys were taken and no spread of contamination was detected.
However, RG&E agreed that management expectations for proper contamination boundary controls had not been met.
Site personnel working in these areas were, subsequently counseled.
Site personnel working in these areas were, subsequently counseled.
ACTION Report 96-0902 ACTION Report 96-0902 dealt with contaminated tools/equipment found in unrestricted area t'ool storage areas. These tools were found as a result of the annual Radiation Protection (RP) surveys of these areas.
ACTION Report 96-0902 ACTION Report 96-0902 dealt with contaminated tools/equipment found in unrestricted area t'ool storage areas.
(1) The reasons for the violation, or,     if contested,   the basis for disputing the violation:
These tools were found as a result of the annual Radiation Protection (RP) surveys of these areas.
RG&E accepts the violation. We agree that problems regarding contamination boundary control and poor radiological work practices have not been programmatically corrected.
(1)
(a)     Safety Injection Pump The area around the safety injections pumps is very congested. Contaminated surface area boundaries are denoted by rad tape. The initial work planned for       ~
The reasons for the violation, or, ifcontested, the basis for disputing the violation:
the area was to inspect and, if necessary, tighten some leaking Swagelok fittings. Typically, the small contamination control area established for this work scope is adequate.
RG&E accepts the violation.
Based on inspection   of the leaking fittings, the work scope was expanded to include tubing replacement. Discussions occurred between the workers and Radiation Protection (RP) technician relative to the expanded work scope, but there was no decision to enlarge the contamination control area boundary to better optimize the work environment. Enlarging the work area would have better accommodated the expanded work scope and eliminated the need to
We agree that problems regarding contamination boundary control and poor radiological work practices have not been programmatically corrected.
(a)
Safety Injection Pump The area around the safety injections pumps is very congested.
Contaminated surface area boundaries are denoted by rad tape.
The initial work planned for
~
the area was to inspect and, ifnecessary, tighten some leaking Swagelok fittings. Typically, the small contamination control area established for this work scope is adequate.
Based on inspection of the leaking fittings, the work scope was expanded to include tubing replacement.
Discussions occurred between the workers and Radiation Protection (RP) technician relative to the expanded work scope, but there was no decision to enlarge the contamination control area boundary to better optimize the work environment.
Enlarging the work area would have better accommodated the expanded work scope and eliminated the need to


Page 4 transfer hand tools and other items in and out of the contaminated area that had previously been established. There was a lack of alertness on the part of the workers and RP technician that the contamination area boundary should have been enlarged for more effective contamination control.
Page 4 transfer hand tools and other items in and out of the contaminated area that had previously been established.
There was a lack of alertness on the part of the workers and RP technician that the contamination area boundary should have been enlarged for more effective contamination control.
The tool removed from the contaminated area was used to tighten a Swagelok nut that had been previously smeared and was free of loose contamination.
The tool removed from the contaminated area was used to tighten a Swagelok nut that had been previously smeared and was free of loose contamination.
Athough full compliance to contaminated area boundary control was lacking, smearing the nut was a positive step which is representative of ongoing efforts at the work area to help minimize the spread of contamination. The rags, wire brush, and wrench should have been bagged prior to removal from the contaminated area.
Athough full compliance to contaminated area boundary control was lacking, smearing the nut was a positive step which is representative of ongoing efforts at the work area to help minimize the spread of contamination.
A contributing factor was the small contaminated area boundary. An enlarged boundary would have eliminated the need to transfer these items in and out of the contaminate'd area. Thus, bagging prior to final removal would have been accomplished as a standard, acceptable work practice, if the contaminated area had been properly enlarged.
The rags, wire brush, and wrench should have been bagged prior to removal from the contaminated area.
Leak from Flow Transmitter FI-116 It is not known who placed the absorbent towel under the transmitter, nor how long the towel had been there before the NRC inspector identified the problem. RG&E acknowledges that an absorbent towel is not an appropriate method for containing contaminated liquid. This is an unacceptable work practice. A catch containment or bucket should have been used.
A contributing factor was the small contaminated area boundary.
An enlarged boundary would have eliminated the need to transfer these items in and out of the contaminate'd area.
Thus, bagging prior to final removal would have been accomplished as a standard, acceptable work practice, ifthe contaminated area had been properly enlarged.
Leak from Flow Transmitter FI-116 It is not known who placed the absorbent towel under the transmitter, nor how long the towel had been there before the NRC inspector identified the problem.
RG&E acknowledges that an absorbent towel is not an appropriate method for containing contaminated liquid. This is an unacceptable work practice.
A catch containment or bucket should have been used.
As background for how this situation developed, a Maintenance Work Order had previously identified a boron buildup on a Swagelok fitting to FI-116.
As background for how this situation developed, a Maintenance Work Order had previously identified a boron buildup on a Swagelok fitting to FI-116.
This prompted RP to provide contamination boundary controls to the immediate area adjacent to FI-116. Initially described as a dry boron buildup, the leak progressed to the point of a steady drip. It could not be ascertained at what stage in leak development the absorbent towel was placed under the transmitter.
This prompted RP to provide contamination boundary controls to the immediate area adjacent to FI-116. Initially described as a dry boron buildup, the leak progressed to the point of a steady drip. It could not be ascertained at what stage in leak development the absorbent towel was placed under the transmitter.
Contaminated Area Boundary Control RG&E acknowledges that corrective actions for previously identified poor radiological, work practices and inadequate contamination boundary controls were not effective. There have been additional incidents in these areas. The programmatic requirements need to be strongly reinforced. These incidents are the result of lapses in performance and failure to adhere to the established management expectations and standards.
Contaminated Area Boundary Control RG&E acknowledges that corrective actions for previously identified poor radiological, work practices and inadequate contamination boundary controls were not effective.
There have been additional incidents in these areas.
The programmatic requirements need to be strongly reinforced.
These incidents are the result of lapses in performance and failure to adhere to the established management expectations and standards.


Page 5 Therefore, as discussed in detail under corrective actions, the focus will be on clear and unambiguous expectations for boundary demarcations and control, additional management coaching and counseling, heightened awareness of these expectations, enhanced training, enforcing consistency in application of standards, reinforcement of individual accountability and responsibility, and monitoring to -ensure continuing compliance.
Page 5 Therefore, as discussed in detail under corrective actions, the focus willbe on clear and unambiguous expectations for boundary demarcations and control, additional management coaching and counseling, heightened awareness of these expectations, enhanced training, enforcing consistency in application of standards, reinforcement of individual accountability and responsibility, and monitoring to -ensure continuing compliance.
The corrective steps that have been taken and the results achieved:
The corrective steps that have been taken and the results achieved:
(a)     On February 11/12, 1997, meetings were held with all available members of the Nuclear Operations Group. These meetings provided an opportunity for the Plant Manager to discuss radiological work practices and contamination boundary control. The importance of adherence to procedures and the seriousness of lapses in acceptable practices concerning contamination boundary control was personally conveyed by plant management.
(a)
(b)     At the request of Maintenance Supervision, the Ginna Station Principal Health Physicist met with members of appropriate shops to outline concerns with improper contamination boundary control and to review station requirements and management expectations. Separate meetings were held with each of the following shops:
On February 11/12, 1997, meetings were held with all available members of the Nuclear Operations Group.
These meetings provided an opportunity for the Plant Manager to discuss radiological work practices and contamination boundary control.
The importance of adherence to procedures and the seriousness of lapses in acceptable practices concerning contamination boundary control was personally conveyed by plant management.
(b)
At the request of Maintenance Supervision, the Ginna Station Principal Health Physicist met with members of appropriate shops to outline concerns with improper contamination boundary control and to review station requirements and management expectations.
Separate meetings were held with each of the following shops:
Mechanical Maintenance Electrical Maintenance Instrument and Control (I&C)
Mechanical Maintenance Electrical Maintenance Instrument and Control (I&C)
ISAAC Special Projects (c)     A letter was issued by the Plant Manager and Superintendents to all plant personnel, dated March 20, 1997, regarding management expectations for contamination boundary control. This letter emphasized that all personnel are accountable for obeying established radiological boundaries when entering the restricted area. It further emphasized that if instructions are not clear or fully understood, then the planned work should not be initiated, and that it is the worker's responsibility to ensure that all instructions are understood. The letter further stated that any incident of unacceptable radiological work practice will result in a meeting with supervision, and further disciplinary action may be necessary.
ISAAC Special Projects (c)
A letter was issued by the Plant Manager and Superintendents to all plant personnel, dated March 20, 1997, regarding management expectations for contamination boundary control.
This letter emphasized that all personnel are accountable for obeying established radiological boundaries when entering the restricted area.
It further emphasized that ifinstructions are not clear or fully understood, then the planned work should not be initiated, and that it is the worker's responsibility to ensure that all instructions are understood.
The letter further stated that any incident of unacceptable radiological work practice willresult in a meeting with supervision, and further disciplinary action may be necessary.


Page 6 (3) The corrective steps that will be taken to avoid further violations:
Page 6 (3)
The corrective steps that will be taken to avoid further violations:
The Radiation Protection (RP) Group has been assigned responsibility to coordinate implemention of all corrective actions discussed below.
The Radiation Protection (RP) Group has been assigned responsibility to coordinate implemention of all corrective actions discussed below.
(a)     Procedures will be reviewed, and revised as appropriate, to provide and unambiguous management direction. Any changes will           'lear clearly state acceptable practices for contamination boundary control.
(a)
Procedures willbe reviewed, and revised as appropriate, to provide
'lear and unambiguous management direction.
Any changes will clearly state acceptable practices for contamination boundary control.
In addition, any changes will include clear definitions of the various types of acceptable contamination boundary markers.
In addition, any changes will include clear definitions of the various types of acceptable contamination boundary markers.
(b)     Contamination boundary control issues will be discussed at regularly scheduled shop meetings by Maintenance Supervision, to reinforce its importance. Periodically, RP personnel will be requested to attend these meetings to provide clarification and foster increased communications between groups.
(b)
(c)     RP Supervision has directed the RP staff and RP technicians to provide strong coaching to radiological workers. This is being done to ensure RP personnel are effective in assisting workers in maintaining effective contamination boundary control. When practicable, assigned RP personnel are expected to be in the work area when work activites are occurring within contaminated areas, to ensure management expectations are being met.
Contamination boundary control issues willbe discussed at regularly scheduled shop meetings by Maintenance Supervision, to reinforce its importance.
(d)     Training Work Requests have been initiated to provide enhanced training in contaminated area situations.
Periodically, RP personnel willbe requested to attend these meetings to provide clarification and foster increased communications between groups.
(e)     A Root   Cause Analysis is being performed to identify other factors that have contributed to poor radiological work practices in the past.
(c)
Corrective actions, if needed, will address these factors, to assist in developing other appropriate means to strengthen the programmatic requirements and to increase compliance with these requirements.
RP Supervision has directed the RP staff and RP technicians to provide strong coaching to radiological workers.
I (f)     As a joint effort between Maintenance, RP, and Nuclear Training, "Project Boundary" has been established. Major attributes of this project include:
This is being done to ensure RP personnel are effective in assisting workers in maintaining effective contamination boundary control.
When practicable, assigned RP personnel are expected to be in the work area when work activites are occurring within contaminated
: areas, to ensure management expectations are being met.
(d)
Training Work Requests have been initiated to provide enhanced training in contaminated area situations.
(e)
A Root Cause Analysis is being performed to identify other factors that have contributed to poor radiological work practices in the past.
Corrective actions, ifneeded, willaddress these factors, to assist in developing other appropriate means to strengthen the programmatic requirements and to increase compliance with these requirements.
I (f)
As a joint effort between Maintenance, RP, and Nuclear Training, "Project Boundary" has been established.
Major attributes of this project include:
Communication of management expectations Boundary Control policies, that are easy to use Training for ALLgroups on revisions to boundary control policies
Communication of management expectations Boundary Control policies, that are easy to use Training for ALLgroups on revisions to boundary control policies


Page 7 Reinforcing and rewarding good behaviors Revising Training programs Train contractors (who work during outages) to the same level as RGB'orkers Verify adequacy of these actions against predetermined indicators (g)     An independent EQectiveness Review will be conducted to verify the adequacy of the above listed corrective actions. This review will be completed by October, 1997.
Page 7 Reinforcing and rewarding good behaviors Revising Training programs Train contractors (who work during outages) to the same level as RGB'orkers Verifyadequacy ofthese actions against predetermined indicators (g)
(4) The date when full compliance will be achieved:
An independent EQectiveness Review willbe conducted to verify the adequacy ofthe above listed corrective actions.
Full compliance has been achieved as of March 20, 1997, when short term corrective actions, including heightened awareness and rest'atement of management expectations, were completed. Further long term enhancements, as discussed in corrective actions (a) through (g) above, will result in a more e6ective program.
This review willbe completed by October, 1997.
Very     ly yours, Robert C. Mecredy XC: Guy S. Vissing (Mail Stop 14C7)
(4)
Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19046
The date when full compliance willbe achieved:
        'h Ginna Senior Resident Inspector}}
Full compliance has been achieved as ofMarch 20, 1997, when short term corrective actions, including heightened awareness and rest'atement ofmanagement expectations, were completed.
Further long term enhancements, as discussed in corrective actions (a) through (g) above, willresult in a more e6ective program.
Very
: lyyours, Robert C. Mecredy XC:
Guy S. Vissing (Mail Stop 14C7)
Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19046
'h Ginna Senior Resident Inspector}}

Latest revision as of 09:48, 8 January 2025

Responds to NRC Re Violations Noted in Insp Rept 50-244/97-01 on 970105-970223.Corrective Actions:Held Meetings on 970211-12 W/Available Members of Nuclear Operations Group to Discuss Radiological Work Practices
ML17264A872
Person / Time
Site: Ginna Constellation icon.png
Issue date: 04/29/1997
From: Mecredy R
ROCHESTER GAS & ELECTRIC CORP.
To: Vissing G
NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-244-97-01, 50-244-97-1, NUDOCS 9705070042
Download: ML17264A872 (22)
v • d • e


Text

JAN-11-1988 87: 14 U.S.

NRC GINNA 315 524 6937 P.82 AND ROQIESItR 64S AhQElFCTRIC CORPORAIION ~ 8P FASTAVEMIFROCIIESIER,PI Y. MiQP4%1 ARFAOAF/6666 2250 808ERT C. MECREDY Vice lresdenl Nvdcer operol~

U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Guy S. Vissing Project Directorate I-l Washington, D.C. 20555 April29, 1997

Subject:

Reply to a Notice of Violation NRC Inspection R'eport 50-244/97-01, dated March 25, 1997 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Vissing:

Rochester Gas and Electric (RG&E) provides this reply to the Notice of Violation (VIO 50-244/97-01-02) submitted as an enclosure to a leer from Lawrence T. Doerflein, USNRC, to Robert C. Mecredy, RG&E, dated March 25, 1997.

As a result of an inspection conducted from January 5 to February 23, 1997, the following violation of NRC requirements was identified. In accordance with the Enforcement Policy (NUREG-1600), the violation is listed'elow:

"10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures be established to assure that conditions adverse to quality, such as.deficicncies and deviations are promptly identified and corrected.

Contrary'to the above, the licensee failed to correct problems regarding contamination

'oundary control and poor radiological work practices noted in NRC Inspection Report Nos.

50-244/94-29 and 50-244/96-11, and RG&E ACTION Report No. 96-0902 dated September 27, 1996, as evidenced by the following:

February 9, 1997, maintenance tools were removed from a designated contamination area on the A-Safety Injection pump.

Several rags and a wire brush that had been used inside an area with loose smearable surface contamination were allowed to straddle across the boundary marker line and extend into an uncontaminated area.

These items were not surveyed prior to being removed from the contaminated area.

Other wrenches and tools that had been used inside a contaminated area were removed and placed on a clean surface without having been bagged or surveyed for contamination beforehand.

JAN-11-1988 87: 14 U. S.

NRC GINNA 315 524 6937 P. 83 Page 2 2)

February 17, 1997, a leak from a fitting on the transmitter of a flow instrument (FI-116) was dripping from inside a contaminated area onto a clean fioor surface that was designated as uncontaminated.

A towel had been placed on the fioor was collecting the leakage (sic), but the towel was saturated with the radioactive fiuid. Vfater was fiowing away from the towel to a low point in the floor, forming a puddle, and contaminating previously clean fioor areas up to 2700 dpm/100cm'.

No coHecuoa device was in place that could prevent the spread of contaminated water to uncontaminated areas.

The radiological protection technician on duty at the time was aot aware of this condition.

BACKGROUND 1.

Inspection Report 94-29 NRC Inspection Report 94-29 dealt with review of accessible areas of the plant to verify that high radiation doors were locked, and radiological postings were posted as required.

Some variability in the use of contamination bouadary demarcation tape (rad tape) was noted.

In some areas, rad tape was used on the fioor to define the contamination area boundary marker line, and in other areas this was not used.

For example, for one area a contamination rope barricade and posting were used without a floor rad tape boundary marker line.

The inspector also noted an extension cord and a hose running from a clean gaea into a, contaminated area without a clear definition of the clean or contaminated portion of the cord and hose.

Both the cord and hose had been pulled loose during the work evolution and the original position of the cord and hose could not be determined.

RGErE reestablished a clear contamination boundary marker line and stated that the use of rad tape would be reevaluated.

NRC Inspection Report 96-11 As reported in NRC Inspection Report 96-11, NRC inspectors observed a

work area with some work partially conducted inside a roped-off contamination area.

The inspector noted that several equipment service lines and power cords were not secured within thc contamination area.

Significant amounts of tape, grinding dust, and miscellaneous debris generated from welding and grinding work had Mea to the floor and were accumulating outside the contamination area boundary.

The step-off pad for exiting the contamination area was not securely attached to the floor. Several buckets that

Page 3 were used to collect contaminated fluids were not labeled properly.

NRC inspector also noted additional contanunation boundary control concerns, where loose bags and papers within the contamination area were allowed to collect on the floor and extend across the boundary marker line.

Cords and test leads were not secured to thc fioor to prevent them from canying contamination out of the area.

When notified by the NRC inspector of this condition, RG&E personnel immediately cleaned up the debris in and outside of the contamination area and secured the service lines to the floor to prevent thein from being moved across the boundary marker line. Radiological surveys were taken and no spread of contamination was detected.

However, RG&E agreed that management expectations for proper contamination boundary controls had not been met.

Site personnel working in these areas were subsequently counseled.

3.'CTION Report 964902 ACTION Report 96-0902 dealt with contaminated tools/equipment found in unrestricted area tool storage areas.

These tools were found as a result of the annual Radiation Protection (RP) surveys of these areas.

(1)

The reasons for the violation, or, ifcontested, the basis for disputing the violation; RG&E accepts the violation. We agree that problems regarding contamination boundary control*and poor radiological work practices have not been programmatically corrected.

(a)

Safety Injection Pump The area around the safety injections pumps is very congested.

Contaminated surface area boundaries are denoted by rad tape.

The initial work planned for the area was to inspect and, ifnecessary, tighten some leaking Swagelok fittings. Typically, the small contamination control area established for this work scope is adequate.

Based on inspection of the leaking fittings, the work scope was expanded to include tubing replacement.

Discussions occurred between the workers and Radiation Protection (RP) technician relative to the expanded work scope, but there was no decision to enlarge the contamnation control area boundary to better optimize the work environment.

Enlarging the work area would have better accouunodated the expanded work scope and eliminated the need to

JAN-11-1988 87: 16 U.S.

NRC GINNA 315 524 6937 P.85 Page 4 transfer hand tools and other items in and out of the contaminated area that had previously been established.

There was a lack of alertness on the part of the workers and RP technician that the contamination area boundary should have been enlarged for more effective contamination control.

The tool removed from the contaminated area was used to tighten a Swagelok nut that had been previously smeared and was free of loose contamination.

Athough full compliance to contaminated area boundary control was lacking, smearing the nut was a positive step which is representative of ongoing efforts at the work area to help minimize the spread of contamination.

The rags, wire brush, and wrench should have been bagged prior to removal from the contaminated area.

A contributing factor was the small contaminated area boundary.

An enlarged boundary would have eliminated the need to transfer these items in and out of the contaminated area.

Thus, bagging prior to final removal would have been accomplished as a standard, acceptable work practice, ifthe contaminated area had been properly enlarged.

(b)

Leak from How Transmitter FI-116 It is not known who placed the absorbent towel under the transmitter, nor how long the towel had been there before the NRC inspector identified the

problem, RG&E acknowledges that an absorbent towel is not an appropriate method for containing contaminated liquid. This is an unacceptable work practice.

A catch containment or bucket should have been used.

As background for how this situation developed, a Maintenance Work Order had previously identified a boron buildup on a Swagelok fitting to Pl-116.

This prompted RP to provide contamination boundary controls to the immediate area adjacent to Fl-116. Initiallydescribed as a dry boron buildup,

'he leak progressed to thc point of a steady drip. It could not be ascertained at what stage in leak development the absorbent towel was placed under the transmitter.

(c)

Contaminated Area Boundary Control RG&E acknowledges that corrective actions for previously identified poor radiological work practices and inadequate contamination boundary controls were not effective.

There have been additional incidents in these areas.

The programmatic requirements need to be strongly reinforced.

These incidents are the result of lapses in performance and failure to adhere to the established management expectations and standards.

JAN-11-1988 87: 17 U. S.

NRC GINNA 315 524 6937 P. 86 Page 5 clear and Therefore, as discussed in detail under corrective actions the fo

'0 be cus wl 011 additional mana e

and unambiguous expectations for boundary demarcat'ious an

control,

'n management coaching and counscliag, heightened awareness of th anced training, enforcing consistency in application of ness 0 cse standards, reinforcement of individual accountability and responsibility, and monitoring to ensure continuing compliance.

The corrective steps that have been taken and the results achieved:

(a)

On February 11/12, 1997, meetings were held with all available members of the Nuclear Operations Group.

These meetings provided an opportunity for the Plant Manager to discuss radiological work adherence to practices and contamination boundary control.

The im importaace of a

crence to procedures and the seriousness of lapses in acceptable practices coacerniag contamination boundary control was personally conveyed by plant management.

(b}

At the request of'aintenance Supervision the Ginn Stat' irma tion rmcrpal ysicist mct with members of appropriate shops to outline concerns with improper contamination boundary control and to review station requirements and management expectations.

Separate meetings were held with each of the followiag shops:

Mechanical Maintenance Electrical Maintenance Instrument and Control (E&C)

I&C Special Projects.

(c)

A letter was issued by the Plant Manager'nd Superintend ts t all p

personnel, dated March 20, 1997, regarding management em hasized tha expectations for contamination boundary control. Thi I is etter emp size that all personnel are accountable for obeying established radiological boundaries when entering the restricted

. I furth em hasized t ri area.

t er the p as that ifinstructions are not clear or fullyunderstood th planned work should not be initiated, and that it is the worker's en responsibi ity to ensure that all instructions are understood.

The letter further stated that any incident of unacceptable radiological work practice willresult in a meeting with supervisiou, and further disciplinary action may=be necessary.

JAN-11-1988 87: 17 U.S.

NRC GINNA 315 524 6937 P. 87 Page 6 (3)

The corrective steps that willbe taken to avoid further violations.

The Radiation Protection (RP) Group has been assigned responsibility to coordinate implemention of all corrective actions discussed below.

( )

rocedures willbe reviewed, and revised as appropriate, to provide (a)

Procedur clear and unambiguous management direction.

Any changes will clearly state acceptable practices for contamination boundary control.

In addition, any changes willinclude clear definitions of the various types of acceptable contamination boundary markers.

(b)

Contamination boundary control issues willbe discussed at regularly scheduled shop meetings by Maintenance Supervision, to reinforce its importance.

Periodically, RP personnel willbe requested to attend these meetings to provide clarification and foster increased communications between groups.

(c)

RP Supervision has directed the RP staff and RP techni'd strong coaching to radiological workers.

This is being done to ensure contamina

'P personnel are effective in assisting workers in maintaining ff e ective mination boundary control.

Vfhen practicable, assigned RP personnel arc expected to be iu the work area when work activites are occurring within contaminated areas, to ensure management expectations are being met.

raining Work Requests have been initiated to provide enhanced (d)

Tra'raining in contaminated area situations.

(e)

A Root Cause Analysis is being performed to identify other factors that have contributed to poor radiological work practices in the past.

Corrective actions, ifneeded, willaddress these factors, to assist in eve oping other appropriate means to strengthen the programmatic requirements and to increase compliance with these requirements.

'As a joint effort between Maintenance, RP, and Nuclear Training, "Project Boundary" has been established.

Major attributes of this project include:

Communication of management expectations Boundary Control policies that are easy to use Training for ALLgroups oa revisions to boundary control policies

JAN-11-1988 87: 18 U.S.

HRC GthNA 315 524 6937 P. 88 Page 7 Reinforcing and rewarding good behaviors Revising Training programs Train contractors (who work during outages) to the same level as RGB workers Verifyadequacy ofthese actions against predetermined indicators (g)

An independent effectiveness Review wiHbe conducted to verifythe adequacy ofthe above listed corrective actions.

This review willbe completed by October, 1997.

C (4)

The date when fullcompliance willbe achieved:

Pull compliance has been achieved as ofMarch 20, 1997, when short term corrective actions, including heightened awareness and restatement ofmanagement expectations, were completed.

Purther long term enhancements, as discussed in corrective actions (a) through (g) above, willresult in a more effective program.

Very y yours, Robert C. Mecredy xc:

Guy S. Vissing (Mail Stop 14C7)

Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19046 Ginna Senior Resident Inspector TOTAL P.88

CATEGORY

. 1 1

REGULATORY INFORMATION DISTRIBUTION SYSTEM

( RIDS )

Iy ACCESSION NBR: 970507004 2 DOC. DATE: 97/04/29 NOTARIZED:

NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

05000244 AUTH ~ NAME AUTHOR AFFILIATION ECREDY, R ~ C ~

Rochester Gas

& Electric Corp.

RECIP

~ NAME RECIPIENT AFFILIATION VISSING F G ~

SUBJECT:

Responds to NRC 970325 1tr re violations noted in insp rept 50-244/97-0 1 on 970 1 05-970223

~ Corrective actions: held meetings on 9702 1l-l2 w/avai lable members of Nuclear Operations Group to discuss radiological work practices

~

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR 3 ENCL Q SIZE:

TITLE: General

( 50 Dkt ) -Insp Rept/Notice of Violation Response NOTES: License Exp date in accordance with 1 OCFR2, 2. 109 ( 9/19/72 )

05000244 RECIPIENT ID CODE/NAME PD1-1 PD INTERNAL: AEOD/SPD/RAB DEDRO NRR/DISP/P IPB NRR/DRPM/PECB NUD0 C S-ABS TRACT OGC/HDS 3 ERNAL: LITCO BRYCE, J H

NRC PDR COPIES LTTR ENCL RECIPIENT ID CODE/NAME VISSING, G ~

AEOD TTC

~F CE TE~

NRR/DRCH/HHFB NRR/DRPM/PERB OE DIR RGN1 FILE 01 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL NOTE TO ALL "RIDS" RECIPZENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROI DESK (DCD)

ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 18 ENCL R'

AND y

ROCHESTER GAS ANDElECTRIC CORPORATIOhf

~ 89EASTAVENU~ RO HESTER, Ar.Y Idod9.cr'C

'PEA COD! 7ID5I52.'K ROB"RT C. NtECREDY Vice President Nvcfeor operations April29, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555

Subject:

Reply to a Notice of Violation NRC Inspection Report 50-244/97-01, dated March 25, 1997 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Vissing:

Rochester Gas and Electric (RG&E) provides this reply to the Notice of Violation (VIO 50-244/97-01-02) submitted as an enclosure to a letter from Lawrence T. Doerflein, USNRC, to Robert C. Mecredy, RG&E, dated March 25, 1997.

As a result of an inspection conducted from January 5 to February 23, 1997, the following violation of NRC requirements was identified. In accordance with the Enforcement Policy (NUREG-1600), the violation is listed below:

"10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures be established to assure that conditions adverse to quality, such as deficiencies and deviations are promptly identified and corrected.

Contrary to the above, the licensee failed to correct problems regarding contamination boundary control and poor radiological work practices noted in NRC Inspection Report Nos.

50-244/94-29 and 50-244/96-11, and RG&E ACTION Report No. 96-0902 dated September 27, 1996, as evidenced by the following:

February 9, 1997, maintenance tools were removed from a designated contamination area on the A-Safety Injection pump.

Several rags and a wire brush that had been used inside an area with loose smearable surface contamination were allowed to straddle across the boundary marker line and extend into an-uncontaminated area.

These items were not surveyed prior to being removed from the contaminated area.

Other wrenches and tools that had been used inside a contaminated area were removed and placed on a clean surface without having been bagged or surveyed for contamination beforehand.

9705070042 970429 PDR ADOCK 05000244 8

PDR g[llllllllllllllllllllltll lllllll

Page 2 2)

February 17, 1997, a leak from a fitting on the transmitter of a flow instrument (FI-116) was dripping from inside a contaminated area onto a clean; floor surface that was designated as uncontaminated.

A towel had been placed on the floor was collecting the leakage (sic), but the towel was saturated with the radioactive fluid. Water was flowing away from the towel to a low point in the floor, forming a puddle, and contaminating previously clean floor areas up to 2700 dpm/100cm'.

No collection device was in place that could prevent the spread of contaminated water to uncontaminated areas.

The radiological protection technician on duty at the time was not aware of this condition.

BACKGROUND Inspection Report 94-29 NRC Inspection Report 94-29 dealt with review of accessible areas of the plant to verify that high radiation doors were locked, and radiological postings were posted as required.

Some variability in the use of contamination boundary demarcation tape (rad tape) was noted.

In some areas, rad tape was used on the floor to define the contamination area boundary marker line, and in other areas this'was not used.

For example, for one area a contamination rope barricade and posting were used without a floor rad tape boundary marker line.

The inspector also noted an extension cord and a hose running from a clean area into a contaminated area without a clear definition of the clean or contaminated portion of the cord and hose.

Both the cord and hose had been pulled loose during the work evolution and the original position of the cord and hose could not be determined.

RG&E reestablished a clear contamination boundary marker line and stated that the use of rad tape would be reevaluated.

2.

NRC Inspection Report 96-11 As reported in NRC Inspection Report 96-11, NRC inspectors observed a

work area with some work partially conducted inside a roped-off contamination area.

The inspector noted that several equipment service lines and power cords were not secured within the contamination area.

Significant amounts of tape, grinding dust, and miscellaneous debris generated from welding and grinding work had fallen to the floor and were accumulating outside the contamination area boundary.

The step-off pad for exiting the contamination area was not securely attached to the floor.

Several buckets that

Page 3 were used to collect contaminated fluids were not labeled properly.

NRC inspector also noted additional contamination boundary control concerns, where loose bags and papers within the contamination area were allowed to collect on the floor and extend across the boundary marker line.

Cords and test leads were not secured to the floor to prevent them from carrying contamination out of the area.

When notified by the NRC inspector of this condition, RG&E personnel immediately cleaned up the debris in and outside of the contamination area and secured the service lines to the floor to prevent them from being moved across the boundary marker line.

Radiological surveys were taken and no spread of contamination was detected.

However, RG&E agreed that management expectations for proper contamination boundary controls had not been met.

Site personnel working in these areas were, subsequently counseled.

ACTION Report 96-0902 ACTION Report 96-0902 dealt with contaminated tools/equipment found in unrestricted area t'ool storage areas.

These tools were found as a result of the annual Radiation Protection (RP) surveys of these areas.

(1)

The reasons for the violation, or, ifcontested, the basis for disputing the violation:

RG&E accepts the violation.

We agree that problems regarding contamination boundary control and poor radiological work practices have not been programmatically corrected.

(a)

Safety Injection Pump The area around the safety injections pumps is very congested.

Contaminated surface area boundaries are denoted by rad tape.

The initial work planned for

~

the area was to inspect and, ifnecessary, tighten some leaking Swagelok fittings. Typically, the small contamination control area established for this work scope is adequate.

Based on inspection of the leaking fittings, the work scope was expanded to include tubing replacement.

Discussions occurred between the workers and Radiation Protection (RP) technician relative to the expanded work scope, but there was no decision to enlarge the contamination control area boundary to better optimize the work environment.

Enlarging the work area would have better accommodated the expanded work scope and eliminated the need to

Page 4 transfer hand tools and other items in and out of the contaminated area that had previously been established.

There was a lack of alertness on the part of the workers and RP technician that the contamination area boundary should have been enlarged for more effective contamination control.

The tool removed from the contaminated area was used to tighten a Swagelok nut that had been previously smeared and was free of loose contamination.

Athough full compliance to contaminated area boundary control was lacking, smearing the nut was a positive step which is representative of ongoing efforts at the work area to help minimize the spread of contamination.

The rags, wire brush, and wrench should have been bagged prior to removal from the contaminated area.

A contributing factor was the small contaminated area boundary.

An enlarged boundary would have eliminated the need to transfer these items in and out of the contaminate'd area.

Thus, bagging prior to final removal would have been accomplished as a standard, acceptable work practice, ifthe contaminated area had been properly enlarged.

Leak from Flow Transmitter FI-116 It is not known who placed the absorbent towel under the transmitter, nor how long the towel had been there before the NRC inspector identified the problem.

RG&E acknowledges that an absorbent towel is not an appropriate method for containing contaminated liquid. This is an unacceptable work practice.

A catch containment or bucket should have been used.

As background for how this situation developed, a Maintenance Work Order had previously identified a boron buildup on a Swagelok fitting to FI-116.

This prompted RP to provide contamination boundary controls to the immediate area adjacent to FI-116. Initially described as a dry boron buildup, the leak progressed to the point of a steady drip. It could not be ascertained at what stage in leak development the absorbent towel was placed under the transmitter.

Contaminated Area Boundary Control RG&E acknowledges that corrective actions for previously identified poor radiological, work practices and inadequate contamination boundary controls were not effective.

There have been additional incidents in these areas.

The programmatic requirements need to be strongly reinforced.

These incidents are the result of lapses in performance and failure to adhere to the established management expectations and standards.

Page 5 Therefore, as discussed in detail under corrective actions, the focus willbe on clear and unambiguous expectations for boundary demarcations and control, additional management coaching and counseling, heightened awareness of these expectations, enhanced training, enforcing consistency in application of standards, reinforcement of individual accountability and responsibility, and monitoring to -ensure continuing compliance.

The corrective steps that have been taken and the results achieved:

(a)

On February 11/12, 1997, meetings were held with all available members of the Nuclear Operations Group.

These meetings provided an opportunity for the Plant Manager to discuss radiological work practices and contamination boundary control.

The importance of adherence to procedures and the seriousness of lapses in acceptable practices concerning contamination boundary control was personally conveyed by plant management.

(b)

At the request of Maintenance Supervision, the Ginna Station Principal Health Physicist met with members of appropriate shops to outline concerns with improper contamination boundary control and to review station requirements and management expectations.

Separate meetings were held with each of the following shops:

Mechanical Maintenance Electrical Maintenance Instrument and Control (I&C)

ISAAC Special Projects (c)

A letter was issued by the Plant Manager and Superintendents to all plant personnel, dated March 20, 1997, regarding management expectations for contamination boundary control.

This letter emphasized that all personnel are accountable for obeying established radiological boundaries when entering the restricted area.

It further emphasized that ifinstructions are not clear or fully understood, then the planned work should not be initiated, and that it is the worker's responsibility to ensure that all instructions are understood.

The letter further stated that any incident of unacceptable radiological work practice willresult in a meeting with supervision, and further disciplinary action may be necessary.

Page 6 (3)

The corrective steps that will be taken to avoid further violations:

The Radiation Protection (RP) Group has been assigned responsibility to coordinate implemention of all corrective actions discussed below.

(a)

Procedures willbe reviewed, and revised as appropriate, to provide

'lear and unambiguous management direction.

Any changes will clearly state acceptable practices for contamination boundary control.

In addition, any changes will include clear definitions of the various types of acceptable contamination boundary markers.

(b)

Contamination boundary control issues willbe discussed at regularly scheduled shop meetings by Maintenance Supervision, to reinforce its importance.

Periodically, RP personnel willbe requested to attend these meetings to provide clarification and foster increased communications between groups.

(c)

RP Supervision has directed the RP staff and RP technicians to provide strong coaching to radiological workers.

This is being done to ensure RP personnel are effective in assisting workers in maintaining effective contamination boundary control.

When practicable, assigned RP personnel are expected to be in the work area when work activites are occurring within contaminated

areas, to ensure management expectations are being met.

(d)

Training Work Requests have been initiated to provide enhanced training in contaminated area situations.

(e)

A Root Cause Analysis is being performed to identify other factors that have contributed to poor radiological work practices in the past.

Corrective actions, ifneeded, willaddress these factors, to assist in developing other appropriate means to strengthen the programmatic requirements and to increase compliance with these requirements.

I (f)

As a joint effort between Maintenance, RP, and Nuclear Training, "Project Boundary" has been established.

Major attributes of this project include:

Communication of management expectations Boundary Control policies, that are easy to use Training for ALLgroups on revisions to boundary control policies

Page 7 Reinforcing and rewarding good behaviors Revising Training programs Train contractors (who work during outages) to the same level as RGB'orkers Verifyadequacy ofthese actions against predetermined indicators (g)

An independent EQectiveness Review willbe conducted to verify the adequacy ofthe above listed corrective actions.

This review willbe completed by October, 1997.

(4)

The date when full compliance willbe achieved:

Full compliance has been achieved as ofMarch 20, 1997, when short term corrective actions, including heightened awareness and rest'atement ofmanagement expectations, were completed.

Further long term enhancements, as discussed in corrective actions (a) through (g) above, willresult in a more e6ective program.

Very

lyyours, Robert C. Mecredy XC:

Guy S. Vissing (Mail Stop 14C7)

Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19046

'h Ginna Senior Resident Inspector

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