ML17264A872

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

ML17264A872
Person / Time
Site:	Ginna
Issue date:	04/29/1997
From:	MECREDY R C 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)

See also: IR 05000244/1997001

Text

JAN-11-1988

87: 14 U.S.NRC GINNA 315 524 6937 P.82 AND ROQIESItR 64S AhQElFCTRIC

CORPORAIION

~8P FASTAVEMIF

ROCIIESIER,PI

Y.MiQP4%1 ARFA OAF/6666

2250 808ERT C.ME CREDY Vice lresdenl Nvdcer operol~U.S.Nuclear Regulatory

Commission

Document Control Desk Attn: Guy S.Vissing Project Directorate

I-l Washington, D.C.20555 April 29, 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, 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.(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.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, if the 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.Initially described 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 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: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 if instructions

are not clear or fully understood

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 will result 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 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.()rocedures will be 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 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.(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, 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.

'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 ALL groups 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 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 will be completed by October, 1997.C (4)The date when full compliance

will be achieved: 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, will result 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 of Prussia, PA 19046 Ginna Senior Resident Inspector TOTAL P.88

CATEGORY.1 1 REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RI DS)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 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 2 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 I D CODE/NAME PD1-1 PD INTERNAL: AEOD/SPD/RAB

DEDRO NRR/D I SP/P I PB NRR/DRPM/PECB

N U D 0 C S-A B S T RA C T OGC/HDS 3 ERNAL: L I TCO BRYCE, J H NRC PDR COPIES LTTR ENCL RECIPIENT I D CODE/NAME VI SSING, 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 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: 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, 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.(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.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, if the 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 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.

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 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.

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

will be 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 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.(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, 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.

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 ALL groups 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.(4)The date when full compliance

will be achieved: 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.Very ly 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 of Prussia, PA 19046'h Ginna Senior Resident Inspector