ML20236R303

Ack Receipt of Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/87-15,50-336/87-17 & 50-423/87-14.Ltr Also Addresses Weaknesses Identified During Insp Re Performance of Health Physics Audit

ML20236R303
Person / Time
Site:	Millstone
Issue date:	11/17/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mroczka E NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8711230212
Download: ML20236R303 (2)

See also: IR 05000245/1987015

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NOV 17 1987

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Docket Nos: 50-245

50-336

50-423

Northeast Nuclear Energy Company

ATTN: Mr. E. J. Mroczka

Senior Vice President - Nuclear

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Engineering and Operations Group

P. O. Box 270

Hartford Connecticut 06141-0270

Gentlemen:

Subject:

Combined Inspection Report Nos. 50-245/87-15,50-336/87-17,

50-423/87-14

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Thank you for informing us of your corrective and preventive actions relative

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to the Notice of Violation enclosed with NRC Combined Inspection Report No.

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245/87-15,336/87-17,423/87-14. These actions will be examined during a

future inspection of your licensed program.

Your letter also addresses weaknesses identified during the above inspection

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relative to the performance of Health Physics audits conducted by the NUSCO

Radiological Assessment Branch (RAB).

Concerns were raised with the auditor

qualification process and organizational independence of the auditors from the

area being reviewed.

In your response, you in<'icate that RAB audits of the Health Physics area are

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.not intended to satisfy regulatory audit requirements.

You-indicate that all

regulatory audit requirements are fulfilled by audits performed by the NUSCO

Quality Services Department -(QSD).

Consequently, you state that it is neither

necessary nor your intent to qualify RAB auditors to ANSI N45.2.23-1978 lead

auditor criteria.

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We noted during our review of your response that the above statements do not

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accurately reflect the status of your current audit system. The RAB audits of

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the Health Physics area do in fact fulfill Technical Specification

requirements; this responsibility has been procedurally detailed to the RAB

from the QSD.

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Based on telephone conversation with Messrs. Asafaylo and Kangley of your-

staff, on October 15, 1987, we understand that responsibility for conducting

Technical Specification required audits of the Health Physics area will be

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NOV 17 1937

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Northeast Nuclear Energy

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Company

transferred from the RAB to the QSD as of January,1988. .This should resolve

weaknesses noted relative to auditor qualification and independence.

Please

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contact us if our' understanding of your intended actions is not correct.

Your cooperation with us is appreciated.

Sincerely,

Oririnal Signed By:

Ecnald R. Bailamy

Thomas T. Martin, Director

Division of Radiation Safety

and Safeguards

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cc w/ encl:

W. D. Romberg, Vice President, Nuclear Operations

S. E. Scace, Station Superintendent

D. O. Nordquist, Manager of Quality Assurance

R. M. Kacich, Manager, Generation Facilities Licensing

Gerald Garfield, Esquire

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of Connecticut

bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief

L. Prividy, RI, BV-2

T. Rebelowski, SRI, Millstone 1 & 2

B. Doolittle, LPM, NRR

R. Bores, DRSS

P. Swetland, SRI Haddam Neck

J. Shediosky, SRI, Millstone 3

M. Boyle, LPM, NRR

D. Jaffe, LPM, NRR

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September 18,1987

Docket Nos. 50-245

50-336

50-423

A06752

Re: 10CFR20.203

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U.S. Nuclear Regulatory Commission

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Attn: Document Control Desk

Washington, D.C. 20555

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Gentlemen:

Millstone Nuclear Power Station, Unit Nos.1,2, and 3

Response to Notice of Violation

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On August 19, 1987, (1) the NRC Staff issued a Notice of Violation to the

Northeast Nuclear Energy Company (NNECO). This action was the result of an

unannounced inspection conducted July 6-10, 1987 to review radiation protection

activities associated with the Millstone Unit No. I outage and to review the

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status of the Millstone Nuclear Power Station audit and hot particle program.

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During this inspection, NRC inspectors identified a violation of 10CFR20.203(f)

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(1) and (2).

These regulations require that each container of specified amounts

of licensed material have a durable, clearly visible label bearing the radiation

caution symbol and the word " Caution" or " Danger, Radioactive Material,"

identifying the radioactive contents. Also identified was a violation of Technical Specification 6.11 for Millstone Unit No. I which requires that procedures for

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radiation protection be prepared, approved, maintained and adhered to for all

operations involving personnel radiation exposure.

These

violations are

described in more detail in Attachment 1.

NNECO does not contest these

violations as set forth in the Notice of Violation,

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Although not cited as a violation, the inspectors also identified weaknesses in the

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Millstone Unit No. I posting and control of high radiation areas. These findings,

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taken in conjunction with the above noted violations, were identified as a

condition indicative of a lack of attention to detail, recognition of radiological

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concerns, and appropriate management oversight of radiological activities by the

Health Physics staff.

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NNECO takes a serious view of the Staff assessment and clearly recognizes its

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. responsibility to effectively manage the safe operation of our nuclear generating

plants and the importance of a strong Radiological Controls Program as part of

that responsibility.

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(1)

T. T. Martin letter to E. J. Mroczka, " Combined Inspection Report Nos. 50-

245/87-15, 50-336/37-17, and 50-423/37-14," dated August 19,1987.

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U. S. Nuclear Regulatory Commission

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A06752/Page 2

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September 18,1987

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NNECO believes that the major issue is the need for a more effective

management oversight of this important program. NNECO believes that with

responsibility comes accountability and for that reason has taken disciplinary

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actions involving multiple layers of Health Physics Department line management

at the Millstone Nuclear Power Station. This action consisted of written and

verbal warnings and time off without pay. Disciplinary action was administered

in increasing levels of severity commensurate with increasing levels of organiza-

tional responsibility and accountability. Additional actions taken are provided in

the detailed response to each violation. This response is included as

Attachment 1

Although not part of the disciplinary action taken, it should be pointed out that

NNECO has reduced the layers of management in the Health Physics line

organization by eliminating the position of Radiological Services Supervisor.

This strategy was in the planning phase prior to the foregoing incident and was

conceived as a means of improving station management involvement in radio-

logical activities. This organizational change was made effective August 1,

1987.

During the course of the inspection, the Staff reviewed NNECO activities

relative to implementing a Hot Particle Program. It was pointed out by the

Staff that, although a program was under development at the time of the

inspection, no approved Hot Particle Program was in place. A procedure entitled

" Hot Particle Monitoring and Control" is now approved at the Millstone Nuclear

Power Station.

This procedure was approved September

8,

1987.

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calculation methodology is in the process of being proceduralized. NNECO will

continue to work towards the completion of a comprehensive Hot Particle

Program.

The Staff also reviewed the audit program by evaluating the activities of the

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Northeast Utilities Service Company (NUSCO) Radiological Assessment Branch

(RAB). Although the point is well taken regarding the quality of the activities

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reviewed, it should be pointed out that the program implemented by the RAB is

not intended to satisfy regulatory audit requirements. Regulatory audit require-

ments are fulfilled by the audits performed by the NUSCO Quality Services

Departmen t.

Consequently, it is not necessary to train RAB personnel to meet

ANSI N45.2.23-1978 lead auditor criteria. As such, we do not intend to qualify

RAB personnel to that level. We recognize the need to improve the quality of

the RAB program appraisal activities and have a strategy for accomplishing this

by January 1,1988.

NNECO expects each employee to set a work standard that will result in

achieving operational excellence. This expectation is accentuated where super-

visory personnel are concerned in that they have far reaching and broad scope

responsibility. We are committed to achieving operational excellence by setting

appropriate standards for success and by demanding that such standards are met.

We are confident that our Health Physics program has been truly strengthened

through the experience of thir, evaluation and by the comprehensive actions

taken to prevent recurrences.

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U. S. Nuclear Regulatory Commission

A06752/Page 3

September 18,1987

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We trust you will find our responses to the specific violation satisfactory. Should

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you have any questions concerning the attached information, please contact us.

Very truly yours,

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NORTHEAST NUCLEAR ENERGY COMPANY

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E.3. Mroczka

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Senior Vice President

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By: C. F. Sears

Vice President

cc:

W. T. Russell, Region I Administrator

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M. L. Boyle, NRC Project Manager, Millstone Unit No.1

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T. Rebelowski, Resident Inspector, Millstone Unit Nos. I and 2

D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2

R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3

W. 3. Raymond, Resident Inspector, Millstone Unit No. 3

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STATE OF CONNECTICUT)

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COUNTY OF HARTFORD )

Then personally appeared before me, C. F. Sears, who being duly sworn, did state

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that he is Vice President of Northeast Nuclear Energy Company, a Licensee

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herein, that he is authorized to execute and file the foregoing information in the

name and on behalf of the Licensees herein, and that the statements contained in

said information are true and correct to the best of his knowledge and belief.

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I4otary Pub}WExpires March 31,1988

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My Commiss

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Docket Nos. 50-245

50-336

,!30-423

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A06752

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Attachment 1

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September,1987

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Attachment 1

A06752/Page 1

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Northeast Nuclear Energy Company (NNECO)

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(Docket No. 2451.icensing No. DPR-21)

Response to Notice of Violation

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Violation A

B

1.

Description of Violation

0 CFR 20.203(f)(1) and (2) requires that each container of specified

amounts of licensed material bear a durable, clearly visible label

bearing the radiation caution symbol and the words " Caution" or

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" Danger, Radioactive Material", identifying the radioactive contents.

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Contrary to the above, on July 6,1987, a shipping box containing

radioactive material and located in the railway access area on the

14'6" elevation of the Millstone Unit No. I reactor building was not

labeled as required.

2.

Admission or Denial of Violation

NNECO does not contest the violation as set forth in the Notice of

Violation.

3.

Reason for Violation

This violation occurred because the Health Physics staff responsible

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for the appropriate labeling of containers containing radioactive

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material failed to imp!cment the requirements of station procedures.

Health Physics procedure HP309/2905/3905, section 5.5, identifies

storage requirements for radioactive material and clearly specifies

labeling requirements.

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Because of this specific violation and the additional example of

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labeling and posting deficiencies, NNECO takes the position that the

primary cause of this condition is the failure of Health Physics

supervision to fulfill its responsibility regarding the implementation

of the Radiological Control Program at the Millstone Nuclear Power

Station.

4.

Corrective Action Taken

immediate corrective actions taken by NNECO are detailed below:

a.

All radiologically controlled areas were toured to ensure that

boxes and containers werc labeled in accordance with 10CFR 20.203(f)(1) and (2).

All instances of noncompliance were

immediately corrected.

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Attachment 1

A06752/Page' 2

5.

Corrective Actions to Avoid Future Violations

Disciplinary ' action was taken involving multiple layers of Health

a.

Physics Department line ' management. This action consisted of

written and verbal warnings and time off without pay. These actions

were administered in increasing levels of severity commensurate with

increasing levels of organizational responsibility and accountability.

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b.

A memo dated July 13, 1987 was sent to all Radiation Protection

Supervisors to bring their attention to the requirements for labeling

containers of radioactive material. The Radiation Protection Super-

visor and the Assistant Radiation Protection Supervisors are identi-

fled in this memo as the persons held directly accountable for

assuring that the requirements of this surveillance program are met,

c.

A surveillance program was established by memo dated July 13,1987.

The basic elements of this program require periodic inspection tours

of plant radiological control areas with the results of the inspection

documented, if deficiencies are identified, the corrective actions

taken must also be documented.

d.

Meetings were held with all Health Physics Department Personnel to

discuss the significance of the findings from this NRC inspection and

to stress the responsibility of each individual to~ implement the

Health Physics program in accordance with approved practices.

Violation B

1.

Description of Violation

Technical Specification 6.11 requires that procedures for radiation protec-

tion be prepared, approved, maintained and adhered to for all operations

involving personnel radiation exposure.

Procedure' SHP 4912, Rev.8,

Section 4 requires, in part, that workers be responsible for "... reading,

understanding, initialing and following RWP instruction." Section 8 of

procedure SHP 4912 also requires, in part, that "...no further work shall be

performed under an RWP once it is terminated or expired..."

Contrary to ti$e above, during the week of July 6,1987, multiple

a.

workers initialed and worked on Radiation Work Permit (RWP) #4348,

without reviewing the latest Health Physics survey, as required by

the RWP.

b.

Also contrary to the above, on July 7,1987, a worker initialed and

prepared to enter the Unit I drywell on RWP'#4631 in violation of

RWP requirements. Specifically, the worker was not wearing or did

not have in his possession respiratory protection equipment as

required on the RWP.

c.

Also contrary to the above, on July 8,

1987, several workers

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reviewed, initialed, and performed work under an expired RWP.

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Attachment 1

A06752/Page 3

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Specifically, RWP //4786 listed an expiration date and time of July 8,

1987 at 0630. Six individuals initialed and made drywell entries on

RWP #4786 on July 8,1987 at times subsequent to the expiration

time of 0630.

2.

Admission or Denial of Violation

NNECO does not contest the violation as set forth in the Notice of

Violation.

3.

Reason for Violation

This violation also occurred primarily because the Health Physics staff

responsible for the implementation of the Radiological Controls Program

failed to fulfill its responsibility for ensuring that station procedures were

properly implemented.

Adequate Health Physics procedural guidance exists to implement the

requirements of Technical Specification 6.11.

4.

Corrective Action Taken

immediate corrective actions taken by NNECO are detailed below:

Specific RWP discrepancies identified as part of this inspection were

a.

corrected immediately and the workers involved counselled regarding

the proper use of RWP's and their individual responsibility.

5.

Corrective Action to Avoid Future Violations

Disciplinary action was taken involving multiple layers of Health

a.

Physics Department line management.

This action consisted of

written and verbal warnings and time off without pay. These actions

were administered in increasing levels of organizational responsibility

and accountability.

b.

Meetings were held with all Health Physics Department Personnel to

discuss the significance of the findings from this NRC inspection and

to stress the responsibility of each individual to implement the

Health Physics program in accordance with approved practices.

Through increased attention to detail and fulfillment of responsibility

c.

regarding RWP activities by the Health Physics staff it is felt that

NNECO will realize substantial improvement in worker compliance

with program requirements. It is a fact that instances of worker non-

compliance were observed as part of this inspection, however, no

action is planned with regard to those specific events beyond that

already discussed.

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NNECO management will pay particular attention to this issue in the

future and instances of worker noncompliance to RWP requirements

as identified by Health Physics staff and/or others will be thoroughly

investigated and appropriately dispositioned.

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