ML18058B869
| ML18058B869 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/03/1993 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306110323 | |
| Download: ML18058B869 (6) | |
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-Power POWERINli MIC.HlliAN'S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 GB Slade General Manager June 3, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT ~
REPLY TO NOTICE OF VIOLATION - NRC INSPECTION REPORT No. 91011 - AND NRC INVESTIGAlION REPORT No. 3-91-013.
NRC Inspection Report No. 91011, dated July 23, 1991, forwarded the results of a special safety inspection conducted from June 25-27, 1991.
The inspection examined several all~gations of inadequate-implementation of the Radiation Protection and Training programs.
One ~lleg~tion, a ~eliberate hot particle exposure (AMS No. RIII A-0041), was left open..
Further NRC evaluation was conducted under Investigatiori Report 3-91-013-and resulted in a violation dated May 7, 1993.
Our reply to the Notice of Violation is provided in Attach~ent 1 to this letter.
~~dAt--
Gerald B. Slade
-General Manage~
cc Administrator, Region III, USNRC NRC Resident Inspector - Pali s*ades Attachments 9306110323 930603 PDR ADOCK 05000255 G
.PDR A CM5 ENERGY COMPANY
CONSUMERS POWER COMPANY To the best of my knowledge~ information and belief, the contents of this submittal are truthful and complete.
By~
David P Hoffman, Vi e Nuclear Operation Sworn and subscribed to before me this.5~ay of-..,..;~-=--<~=-~
{/
Beverly A. Avery, Nata Jackson County, Michigan My commission expires December 3, 1996 1993.
[SEAL]
.. I
ATTACHMENT I Consumers Power Company Palisades Plant Docket 50-255 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT No. 91011 - RADIATION PROTECTION
. NRC INVESTIGATION REPORT No. 3-91-013 June 3, 1993 3 Pages
. *.--I
1 REPLY TO NOTI_CE OF VIOLATION VIOLATION
- Conditions No. 2.C, 2.D and 3 of Provisional Operating License No. DPR-20 authorizes the licensee, in part, to receive, po~sess, and use in connection with operation of the facility, byproduct, source and special nuclear materials* pursuant to the Atomic Energy Act of 1954, as amended, and 10 CFR Parts 30, 40 and 70.
The listed authorized uses of byproduct and special nuclear materials are:
1500 curies of Polonium-210 as two sealed sources not to exceed 750 curies each; 1000 curies of Cesium-137 as multiple sealed calibration sources and up to 500 mi11icuries per nuclide of any byproduct material with Atomic Numbers 3-83, inclusive, without restriction to chemical and physical form to a total of 10 curies; and possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the faci1 ity.
Contrary to the above, on November 15-16, 1990, the licensee failed to ensure that byproduct material was possessed and used in accordance with the specific purposes described in License Conditions 2.C, 2.D, or 3.
Specifically, a contractor employee placed a radioactjve "hot particle" on the back of another individual and this is not one of the uses of byproduct materials authorized by License Conditions 2.C, 2.D, or 3.
REASON FOR THE VIOLATION On November 15, 1990 (date is best estimate, since no record was found listing the actual date) a contract radiation safety technician placed a hot particle on the back of his sup~rvisor (also~ contract employee) as a practical joke.
He expected the hot particle to alarm the PCM-18. radiation monitor as the supervisor exited the radiologically controlled area.and cause him to be embarrassed.
As the supervisor left the containment access facility (where the incident occurred) he brushed the doorway and the hot particle came off on the door.
The particle was inside a planchet, which was inside a taped closed plastic bag.
The supervisor noticed the plastic bag containing the particle stuck to the door and questioned the technician.
The technician was verbally reprimanded by the supervisor..
The supervisor talked to the contract technictan ~ite coordinator about the incident who then discussed the issue with the acting Health Physics (HP)
Superintendent.
The HP Superintendent was on vacation at the time of the incident. The site coordinator and the acting HP Superintendent decided to terminate the contract technician's employment at the Palisades plant on November )6; 1990 as the result of this incident. Site Security removed access authorization on the same day at the request of the acting HP Superintendent. The acting HP Superintendent also specifically told the site
. coordinator to tell the technician exactly why his employment at Palisades was being terminated.
When the technician's supervisor met the technician at the plant entrance door on the evening of November 16, 1990 he told him he was being laid off to reduce staff. This explanation for termination also appears
..... -* I
. 'v on the technician's "Assignment Completion Report" dated November 16, 1~90.
Consumers Power Company {CPCo) personnel did not ensure the contractor listed the actual reas_on for termination of employment at Pali sades on the report, nor did CPCo personnel document the incident at this time.
2 The HP Superi ritendent returned from vacation around November 30,
- 1990 and reviewed the incident. The decision was made to not document this incident on a corrective action document or Radiological Deficiency Report {RDR) because; radioactive material did not leave the radiation controlled area, no personnel exposure was involved, corrective action (terminated employment) had already been taken, and the incident did not warrant a RDR by his interpretation of the procedure.
The NRC Region III conducted an~inspecti~n (No. 91011) on June 25-27, 1991 as the result of several allegations, one of which was a deliberate hot particle exposure.
The inspection report was received on July 23, 1991 and substantiated the deliberate placement of radioacttve material on the back of an individual. Also stated in the repbrt wa~, "... it appears that the licensee was under an obligation to document this incident in a corrective action document yet failed to do so." Additional inspection efforts would be forthcoming, and the allegation remained open (AMS No. RIII-91-A-0041, Item 1).
A RDR was initiated on August 8, 1991 for this incident to document the event and to address the finding of the NRC Inspection Report.
Corrective actions recommended and taken as a result of the RDR were: terminate employment of the technician (already_done) and review the incident* with all contract technicians at the beginning of the next refueling outage (contract technician Lesson Plan LP-001 and Policy and Practices Working File on August 23, 1991).
The incident was also incorporated into the in-house required technician reading:list on September 3, 1991.
The-same technician was hired at Big Rock Point for their refueling ~utage a year later on November 18, 1991.
Big Rock Point had no knowledge of this individual's involvement in the hot particle 1ncident at Palisades.
To date, we have not h~d any similar events dealing with the unauthorized use of radioactive materi~l.
The root cause of this viol at fon was the poor judgment and lack of.
professionalism exhibited by the contract technician.
A misinterpretation of the requirements by Health Physics Management, in particular, the acting HP Superintendent and HP Superintendent explains the lack of an immediate Corrective Action document. A review of the specifics involved in this incident and the procedural requirements indicates a judgement call was made.
Since the radiological significance was lo~, no licensed material was released and corrective action was already taken, a corrective action document was not prepared.
- Also management did not follow-up to ensure that a person terminated "for cause" at one of our NRC licensed facilities would not be hired at our other
nuclear facility without ari appropriate management review of the circumstances. A syst~m is in place to accomplish this control, but it is apparently not well known by all of CPCo supervision. A flag on the CPCo Nuclear Program Admittance System (NUCPAS) is used. to designate company or contract employees who are terminated "for cause." This system was not understood or used by Health Physics management at the time of this incident and as a result, no questi~ni were raised when the contract technician reported for work at the Big Rock Point facility.
CORRECTIVE ACTIONS AND RESULTS ACHIEVED As a result of *the Radiological Deficiency Report initiated to document the event and to address the finding identified in the NRC Inspection Report (IR
.91011}, the following actions were completed:
3
- 1. The contract technician's unescorted access authorization and subsequent employment at Palisades was terminated on November 16, 1990 as a result of the incident.
- 2.
The incident was reviewed with all contract technicians prior to the start of the 1992 refue 1 i ng outage.*.
- 3.
The incident was incorporated into the in~house required technician reading list on September 3, 1991.
NOTE:
A*different contract technician supplier is currently being used at Palisades. Although this incident was not the sole reason for the change, it was a*consideration in the decision.
No similar incidents have occurred.
. CORRECTIVE ACTION TO AVOID FUTURE NON-COMPLIANCE
- 1. This technician is* now flagged in our access control program (NUCPAS) which includes Big Rock Point Nuclear Plant, as having access revoked "for cause." Management review is required prior to rehiring this technician.*
- 2. A memo to all Nuclear Operations Department Supervision has been provided on how to properly document the revocation of unescorted access "for cause" so that NUCPAS is updated correctly.
DATE OF FULL COMPLIANCE Full compliance has been achieved.