ML17264A872
| ML17264A872 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| 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) | |
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
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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
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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