JAFP-97-0251, Submits Response to Violations Noted in in Rept 50-333/97-04 on 970525.Corrective Actions:Individual Decontaminated & interviewed,follow-up Contamination Surveys Performed & Individual Placed on Radiological Hold
| ML20196H097 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/17/1997 |
| From: | Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-333-97-04, 50-333-97-4, JAFP-97-0251, JAFP-97-251, NUDOCS 9707230328 | |
| Download: ML20196H097 (6) | |
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J:mes A. FitzP; trick Nucirr Pow:r Ptnt 266 Lake Road P.O. Box 41 Lycoming, New York 13093 315 342-3840 4 NewYorkPower uicnoei J. coiome
& Authority site executive omcer July 17, 1997 JAFP-97-0251 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C. 20555
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50 333 Reply to Notice of Violation NRC Insnection Renort 50-333/97-04
Dear Sir:
In accordance with the provisions of 10 CFR 2.201, Notice of Violation. the Authority submits a response to the notice transmitted by your letter dated June 13,1997. Your letter refers to the results of an inspection completed at the James A. FitzPatrick Nuclear Power Plant on May 25,1997.
This violation concerns failure of radiation workers to follow radiation protection requirements. Poor human performance was the cause of workers failing to follow requirements. The JAF plant leadership team has recognized severalincidents attributed to personnel error. We have completed an evaluation of human performance documented in the Human Performance Team Report. The report identifies causes of personnel errors and recommendations to prevent future events. We have also developed a Radiation Work Excellence Plan that is focused on improving human performance consistent with the recommendations of the Human Performance Team Report. We understand the broad implications of this violation and have long-term corrective action plans underway. provides the description of the violation, reason for the violation, the corrective actions that have been taken and the results achieved, corrective actions to be taken to understand the broader implications of the violation and avoid further violations, and the date of full compliance, i
There are no commitments contained in this report.
gd if you have any questions, please contact Mr. Arthur Zaremba at (315) 349-6365.
Very truly yours, lf lllllflllhllhlf s
MICHA J. COLOMB STATE OF NEW YORK COUNTY OF OSWEGO MJC: RAP:las Subscribed and sworn to before me cc: next page this fl* day of duKi>,1997.
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PDR NotaryMtrTLU MORMRTY 84965820 o%')O44 Notary Pub 5c. State of New York Ouaifiedin Oswego Coun Cownission Expires Apri30,
cc:
Regional Administrztor
' U.S. Nucl:Ir R gul: tory Commission c.
475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector.
U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Ms. K. Cotton, Acting Project Manager Project Directorate 1-1 Division of Reactor Projects 1/11 1
- U. S. Nuclear Regulatory Commission Mail Stop 1482'
. Washington, D.C. 20555 1
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REPLY TO NOTICE OF VIOLATION NRC Inspection Report 97-04 Violation During an NRCinspection conducted from April 13 to May 25,' 1997, a violation of NRC
. requirements was identified. ' In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,' NUREG 1600, the violation is listed below:
Technical Specification 6.11 requires, in part, that procedures for personnel radiation protection shallbe prepared and adhered to for allplant operations. Administrative i
Procedure (AP)-07.00 (Rev. O), Radiation Protection Program, Section 6.1.5, states that radiation workers shall comply with radiation protection instructions.
Contrary to the above, radiation workers did not comply with radiation protection instructions as identifiedin the following examples:
(1) On December 7,1996, two radiation workers did not adhere to the radiation work permit, disregarded radiologicalposting requirements and one worker improperly i
used the portal monitor. These practices resulted in an individual becoming I
contaminated; and (2) On April 16,1997, in two separate incidents, radiation workers escorted three visitors into the plant cable tunnel which is a radiologically controlled area (RCA).
The entrance to the cable tunnel was posted with a yellow and magenta sign which stated ' Caution Radioactive Material' that the area was an RCA, that only i
authorized personnel were to enter, and that a thermoluminescent dosimeter (TLD) was required for entry. The visitors were not authorized or monitored for radiation exposure as required by procedure.
This is a Severity LevelIV violation (Supplement IV).
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Admission or Denial of the Alleaed Violation i
The Authority agrees with this violation.
Reasons for the Violation The cause for the violation was personnel error. The performance factors leading to these errors were:
Personnel failed to accept personal responsibility to adhere to written and posted instructions resulting in unauthorized access to radiological areas, in the first example, workers failed to obtain a radiation protection briefing prior to entry into a contaminated area, in the second example, the workers failed to adhere to postings in that they entered a radiological area without required dosimetry for their escorted visitors.
Personnel failed to use available resources, the technical assistance of the radiation protection staff, to perform the tasks appropriately.
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__m REPLY TO NOTICE OF VIOLATION g
NRC Insoection Report 97-04 2
in both' cases the radiological postings were evaluated and determined to be adequate.
The conclusion was made that the individuals, in both cases, were not attentive to posted instructions.
Individuals performed tasks without proper preparation, including failing to obtain radiological briefings and work permits.
Corrective actions for previous similar radiological control boundary incidents were inadequate in that extent of condition was not effectively addressed. Although an adverse trend DER was issued, earlier recognition of the adverse trend could have prevented the second incident.
Corrective Actions That Have Been Taken immediatelv followina the event in examole 1:
The individual who alarmed the security portal monitor:
The individual was decontaminated and interviewed.
Follow up contamination surveys were performed to ensure there was no further spread of contamination.
This individual was placed on radiological hold temporarily rescinding his authorization to access the RCA. During investigation of the improper use of the portal monitor, the-individual's employment at JAF ended.
The second individual who did not adhere to the radiation work permit was provided job performance counseling.
Additional corrective actions taken for examole 1:
Operating shift workers were presented radiological briefing expectations to assure utilization of radiation protection' resources.
Plant staff was. informed of the event, the cause of the event, and the requirement to follow written and posted instructions.
Immediatelv followina the event in examole 2:
Technicians were posted at RCA access / egress points to ensure no further unauthorized entries occurred.
The cable tunnel was toured by security personnel to ensure no unauthorized personnel
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were in the area.
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-REPLY TO NOTICE OF VIOLATION i
NRC Inspection Report 97-04
. The ashorts were placed on radiological hold temporarily rescinding their authorization i
- for access into the RCA.
The escorts were counseled by radiation protection personnel and their supervisors.
Second physical barriers were placed at RCA entrances to prevent recur: 1nce of this i
type of event. Second barriers currently include radiation ropes or swing gates with l
signs, in addition to normal radiological postings.
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d' An evaluation was performed to determine if other similar events had occurred. A listing of all visitors was compiled and compared to security access records. No.
additional deviations were identified.
E Additional corrective acticce taken for examole 2.
j The individuals who inappropriately escorted visitors into the RCA were disciplined in accordance with Human Resources policies.'
l Plant personnel were immediately notified by memorandum of this particular incident description and radiological consequences.
Results Achieved l
i The Authority believes the corrective actions taken were effective in preventing recurrence. The FitzPatrick staff awareness of the issues relating to these events has been heightened. The Authority is continuing to reinforce the importance of compliance with radiation protection performance standards by increasing radiation worker j
involvement through our Radiological Work Excellence Plan.
Corrective Actions to Be Taken to Understand the Broader imolications of These Violations As previously stated in our 2/21/97 (JAFP 97-0061) correspondence to the NRC, in an effort to improve all aspects of operation at the James A. FitzPatrick Nuclear Power Plant, a team of line personnel was formed and has evaluated human performance related events at the site. The corrective actions developed by the team are being implemented to ensure continued performance improvement.
In addition, The Radiological Work Excellence Plan was developed and issued May 21, 1997. This plan is also focused on improving human performance. The actions are carried out by teams and involve radiation workers in many departments at FitzPatrick. The strategy.of this plan is similar to the strategy used in the radiation protection improvement program. The Excellence Plan uses recent successes in radiation work practices as a guide for plant workers in all departments. Worker involvement, program ownership and personal integrity will help achieve high standards of performance and eliminate personnel errors that lead to events.
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l REPLY TO NOTICE OF VIOLATION NRC Insoection Reoort 97-04 Guidelines'have been prepared to improve control over groups of visitors. These guidelines will be used in the future to ensure better control and monitoring of visitor activities.
Visitors not on official business, are now required to receive Site Executive Officer approval prior to site restricted area access.
Extent of condition evaluations will be considered for all Deviation and Event Reports (DERs). Documentation of the evaluation will be included in the appropriate DER closure packages.
l Date When Full Comoliance Will Be Achieved Management expectations for improving.iuman performance have been and continue to be reinforced. Full compliance was achieved on April 16,1997 when the visitors exited the RCA.
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