JAFP-95-0336, Responds to Insp Rept 50-333/95-10 of Radiation Protection Activities

Responds to Insp Rept 50-333/95-10 of Radiation Protection Activities

ML20086P879
Person / Time
Site:	FitzPatrick
Issue date:	07/20/1995
From:	Harry Salmon POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
JAFP-95-0336, JAFP-95-336, NUDOCS 9507270192
Download: ML20086P879 (7)

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' 's ' James A. FitzPatrick Power Plert LyoW. New York 13083 315 342.3840 M 'New York Power 4# Authority g,,,y ,, ,,,,,,, 3,,

sa. ex.c*. ome.,

July 20, 1995 JAFP-95-0336 -

Mr. Richard W. Cooper II Director, Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road l King of Prussia, PA 19406

SUBJECT:

James A. FitzPatrick Nuclear Power Plant  !

Docket No. 50-333 Response to NRC Inspection Report 50-333/95-10

Dear Mr. Cooper:

i Mr. J. Furia of your staff conducted an inspection of radiation protection activities at the James A. FitzPatrick Nuclear Power Plant (JAFNPP) on May 15-19,1995 documented in NRC Inspection Report 50-333/95-10 dated May 26,1995. Contained in your letter was a request for the Power Authority to outline plans for improving performance in the areas cited. This letter is being submitted to provide that information.

Attachment 1 contains detailed responses to the specific areas identified.

If you have any questions, please contact Mr. Art Zaremba at (315) 349-6365. ,

Very truly yours, cs M

flarry P. Salmon,Jr[

HPS:GB:las cc: see next page

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cci U.S Nuclcar R gulatory;Co2miecion l Docuncnt Control D3ck 9" Mail-Station-P1-137 e

Washington, DC 20555 ,

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. - Mr. Thomas T. Martin i Regional Administrator.

Region l' .

, U.S. Nuclear Regulatory Commission-475 Allendale-Road .;

King of Prussia, Pa 19406  ;

' Office of the Resident. Inspector U.S. Nuclear Commission .

P.O.' Box 136- ,

Lycoming, NY 13093 - i Mr. C.E. Carpenter, Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 B2 i Washington, DC 20555  ;

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s ATTACHMENT 1 RESPONSE TO NRC INSPECTION REPORT 95-10 d

Cited in your report were five weaknesses within the radiation protection program which the commission believes require cqntinued attention to assure appropriate and timely correction.

The Power Authority agrees with your assessment and is committed to correcting fundamental causes for the weaknesses. Resources are being allocated for a successful resolution to these issues.

Senior management will continue to be involved with the corrective actions. Results from these efforts, while not immediate, will be effective and long lasting.

Included below are those areas referenced in your Inspection Report and the corrective actions being developed and/or implemented at JAFNPP.

A. Previously identified problems concerning worker compliance with plant radiological protection procedures continue to be identified by NYPA staff.

• Improvements have been made in NYPA Management and staff accountability, involvement and ownership of Radiation Protection (RP) worker practices through the following initiatives: j

- The Radiological Hold process requires line supervisors to be accountable for correcting i radiation worker performance problems. When an  :

inappropriate worker practice is identified, the l worker is counseled on the spot or placed on 1 Radiological Hold, prohibiting entry into the radiological controlled area (RCA). Once on hold, a briefing is conducted between the worker's supervisor, th'e worker and Radiation Protection personnel to retiew the practice. The radiation worker is then counseled by the supervisor on RP performance requirements and responsibilities prior to re-entry into the RCA.

- Enhanced Radiation Worker Training (ERW) is being provided to multi-discipline groups including Operations, Maintenance, Instrument and Controls, and Engineering. The training objective is three-fold. Emphasis is placed on teamwork, compliance with radiation protection requirements, and reinforcing consistent application of radiation worker practices. ERW Training has commenced and is scheduled through October 1996.

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. .' ATTACHMENT l' DRAPONSE TO'NRC INSPECTION REPORT 95 i A.(cont)- - Management. has placed stronger emphasis on ~ the Management Observation' Program. Through the' expanded use of radiological. work practice' i observations (Work Practice Observation

Checklist); line' supervisors have increased their field presence, awareness _and' attention to. "

radiological worker performance. Increased coaching.has resulted in improved trends in >

radiological worker performance and practices.

. ' Monitoring of Deficiency EventfReports (DER) is '

JAFNPP's-corrective. action' program performed.

includes: Daily; reviews and' screening:of DERs by; the Plant Leadership Team; weekly DER reviews by the Performance Enhancement Review Committee (PERC) of human performance related events; the ,

inclusion of all open radiation protection.related-DERs in the Monthly Radiological Report; and the issuance of a quarterly DER trend report. This report represents a cumulative review of DERs issued, and includes the results of an analysis of RP related DERs. <

- Tailgate meetings are conducted weekly by all departments. Lessons Learned from radiation protection related DERs are included as routine s agenda topics. Managers and supervisors review RP procedures, RP programs and RP standards of ,

performance with their staff.

B. Radiation protecti5n technicians do not always provide proper support to radiation workers. >

• Plant expectations were established.and discussed with the RP technicians. Professional conduct is being '

emphasised through improved communication and coaching.

skills. Observable improvements have been ani! will ,

continue to be made in technician performance in '

support of radiation worker activities.

- A communication and conflict resolution course is being developed for the radiation protection staff. Training is directed towards improving Radiation Protection staff. professionalism when confronted with complex situations requiring RP' technician expertise. This program will commence in-the fall of 1995.

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. ATTACHMENT l' ~

.REEPONSE TO'NRC INSPECTION REPORT 95-10l 2  !

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-B.(cont) ~

- RP technicians participate in each i Enhanced '

Radiation Worker Training course. This ~j

. participation provides the RP: technicians with' j simulated field experience where teamwork, _

compliance with: radiation protection requirements,. I coaching and application of good radiological  ;

worker practices, ara xey to success. j i

C. The radiological protection staff does not always j recognize the positive impact that can result from. t Quality Assurance (QA) audit findings.- -

i e The positive impact'of'QA audits ~is being communicated to the RP staff by the REs Manager and.the  !

Health Physics General supervisor. Management-bas and will continue to communicate the value of QA audits and' .

the role they play in the radiation protection program.

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- The QA staff is assisting the RES Department in organizing and consolidating radiation protection issues and is helping in the resolution of unresolved items.

- Radiation Protection self assessments are.being.

performed in accordance with Administrative Procedure AP-03.07," Internal Appraisal". . The assessments are assigned for completion to all-levels of the radiation protection staff. QA is  !

assisting RES on refining the manner in which  !

these assessments are being performed. Assessment  !

schedules are' presently being developed on a quarterly basis'

- RP technicians have been tasked with performing. l self assessments. Participation in the assessment  ;

program has provided technicians with an increased i awareness of the value of audits and the important role QA plays in a successful radiation protection program.

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~ ATTACHMENT 1 1,. RESPONSE TO NRC INSPECTION REPORT 95-10' t-D. , ' Weaknesses:in radiological procedures-continue to be

' identified by the JAFNPP staff.

• ManagementLagrees that Radiation Protection-Procedures contain weaknesses. Revised radiological procedures will contribute .tolthe -improving

- Laplementation'of the radiation protection program.

- A revised. radiation protection procedure upgrade plan is being implemented. RES stafflis presently L receiving orientation and indoctrination on the-L revised plan. -The. plan implementation schedule.is L divided into various scheduled milestones. 'An F upgrade team comprised.of-RES management, l

administrative, technical and technician personnel are meeting frequently to address procedural L concerns.

- The focus of the revised procedure upgrade. plan is to simplify, clarify, and provide consistent direction leading to user acceptance.and full compliance with radiological procedures.

E. ' The JAFNPP staff has identified instances of

, radiological technicians failing to follow procedures.

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• Compliance with procedures by RP technicians is an issue that is being given full management attention. 4 The requirements for technicians to follow procedures is' repeatedly reinforced by radiation protection and plant management.- The expectation.

being communicated'is-that when a procedure cannot be performed as written,~stop the task, and.get resolution to the issue (s) in question prior to proceeding.

- The RP staff ils performing self-assessments on compliance with procedures. Immediate coaching during self-assessments is being performed'when needed to assure procedure compliance.

- Extensive RP technician training is being provided on Administrative Procedure AP-02.04,

" Control of Procedures". The training will assure that technicians understand:how to revise procedures when required and ensure ownership of procedures. Training is scheduled for completion L .by August 1995.

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ATTACHMENT 1 RESPONSE TO NRC INSPECTION REPORT 95-10 n- i Teams have been established with the support of NYPA's Chief [

. Nuclear Officer to assist in making lasting improvements'to the  ;

JAFNPP Radiation Protection Program. One team consists of  ;

individuals from the corporate. office and the IP-3 Nuclear Power Plant with substantial radiation protection technical experience.  :

This team's purpose is to assure that effect-ive measures are being'taken to improve the radiation protection; program at JAFNPP. The second team consists of. three members of the Employee. Effectiveness Group from the NYPA corporate human resources office. This team's purpose is to improve teamwork.and .

ownership of the radiation protection program by the RP and plant-  !

staff. These teams will continue to support these' objectives

• l until such time NYPA is confident that the RP program at JAFNPP j has reached the performance level where the teams are no longer j required.  ;

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