ML20078E990

Responds to NRC Re Violations Noted in Insp Rept 50-333/94-30.Corrective Actions:Dept Meetings Conducted to Review & Reinforce Mgt Expectations Re Radiation Work Practices Identified in NRC Insp Rept 50-333/94-30

ML20078E990
Person / Time
Site:	FitzPatrick
Issue date:	01/23/1995
From:	Harry Salmon POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
JAFP-95-0028, JAFP-95-28, NUDOCS 9502010236
Download: ML20078E990 (7)

Text

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James A.FitzPatrick l

, Nuclear Power PIent P O. Box 41 l

• Lycoming, New York 13093 l . 315 342-3840

(-

l h e,wWrkPbwer Harry P. Salmon, Jr.

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. hor.ty i ne ioeni uenege, January 23,1995 JAFP-95-0028 Director, Office of Enforcement U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Response to Notice of Violation NRC Inspection Report 50-333/94-30 Gentlemen:

In accordance with the provisions of 10 CFR 2.201, Notice Of Violation, we are submitting our response to notice transmitted by your letter dated December 22,1994.

This refers to the inspection conducted by Mr. J. Furia of your office on December 12-16, 1994, at the James A. FitzPatrick Nuclear Power Plant.

The reason for the violation, the corrective action- that have been taken and the results achieved, the corrective actions to be taken to avoid further violations and the date when full compliance will be achieved for the violation is included in Attachment 2.

Attachment 3 summarizes the commitments contained in this submittal.

If you have any questions, please contact Mr. Michael Colomb at (315) 349-6005.

Very truly yours, l -

Harry P. nlmon, Jr. 8 STATE OF NEW YORK COUNTY OF OSWEGO and sworn to before me  !

Subscrip' thise 21' . day of January,1995 )

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N TAMMY L DANN 4985563 Notary Public, State of New York auantied in oswego co Netary P6blic Commission Expires 8/19/gy 010031 ce: See "*" P 8e ggg2qgggggggag!33 // > I <

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cc: Regional Administrator d

. U.S. Nuclear Regulatory Commission Region I

. 475 Allendale Rocd .

King of Prussia, PA 19406 Office of the Resident Inspector U.S. Nuclear Regulatory Commission '

P.O. Box 136 '

Lycoming, NY 13093 i

i Mr. Eugene Carpenter

. Project Directorate 1-1 Division of Reactor Projects 1/11 <

U.S. Nuclear Regulatory Commission Washington, DC 20555 0

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Attachment 1 j EF1:PONSE TO NOI1CE OF VIOLATION Violation Title 10, Code of Federal Regulations, Part 20.1101, requires, in part, that licensees develop, document and implement a radiation protection program commensurate with the scope and extent of licensed activities.

Contrary to the above, the licensee failed to properly implement its radiation protection  ;

program procedures, as evidenced by the following examoles:

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A. Procedure AP-07.10, Rev 1, Paragraph 8.7.4, requires, ia cart, that plant personnel wear dosimetry while in the restricted area and as directed by  !

radiation protection personnel. Radiation protection personnel direct all ,

wearers of dosimetry to locate all dosimeters (thermoluminescent dosimeters ,

and electronic dosimeters) within six inches of each other on the upper front ,

torso, and that the electronic dosimeter be facing outward. This direction is ,

provided both during the formal radworker training given to employees having i access to the Radiologically Controlled Area (RCA), and & rough the use of l postings located at the RCA entrance. On December 12-13, 1994, ten workers in the RCA were observed having their dosimetry located in places other than  ;

their upper torso, having their TLD located greater than six inches from their electronic cosimeter, and/or having their electronic dosimeter not facing  :

outward.

B. Procedure AP-07.20. Revision 3, Paragraph 6.5, requires, in part, that personnel signed in on a radiation work permit (RWP) must comply with the i requirements contained therein. All radiation work permits for activities in  :

posted contaminated areas contain a block that specifies that whole body monitoring is required upon exiting from contaminated areas. Instructions for l a whole body frisk, posted at the frisker station includes directions that a frisk must be conducted with the probe traveling no greater than 2 inches per  ;

second, and should take approximately 90 seconds. On December 13, 1994, t five workers were oberved frisking in the reactor building track bay after exiting the drywell (a posted contaminated area) at a speed much greater than 2 inches per second and in less than 20 seconde each, and one worker was  ;

observed not frisking at all. ,

C. Licensee Procedure AP-07.10, Rev 1, requires, in part, that upon alarming a  :

portal monitor or whole body frisker, the worker is to use a hand frisker to j check the area, and then re-enter the monitor. If the monitor alarms a second time, the worker must then contact radiation protection for assistance.

Workers may not decontaminate themselves without radiation protection  ;

assistance. On December 14,1994, two workers were observed in the reactor building track bay attempting to decontaminate themselves after having alarmed a whole body frisker, without having contacted radiation protection.

This is a Severity Level IV violation (Supplement IV).

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Attachment 2' i

RESPONSE TO NOTICE OF VIOLATION i Admiteian or Denial of the A11eaed Violation

'Ihe Power Authority agrees with this violation.

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The Reasons for the Violation i The causes for the identified wormer performance issues were:

- A. Managerial Methods - Some radiation worker job performance standards were '

not adequately communicated. Workers were not aware of the impact of their actions on tvsological safety.

i B. Supervisorv Methods - Radiation worker job performance standards were not routinely enforced. Managers, line supervision, and radiation protection staff j were not providing adequate coaching to correct these poor radiation work  ;

practices.  !

C. Change Manngement - Poor implementation of the use of electronic dosimeters ,

contributed to inconsistencies in appropriate placement and orientation. l I

Corrective Actions That Have neen Taken t

1. Department meetings wene conducted to review and reinforce management i expectations regarding radiation work practices identified in NRC Inspection Report No. 94-30. i 1

2. The Radiological and Environmental Services Department (RES) hired six additional personnel to perform monitoring activities at control points and to l coach workers on dosimetry placement prior to entry to Radiological Controlled Areas.

3. Managers and supervisors have been directed by Senior Management to i heighten their awareness of potential radiation work pmetices violations in

• their work areas through increased management observations in accordance with Administrative Procedure AP-03.07, "Intemal Appraisal".

4. Postings have been placed at key locations within the Radiological Controlled  ;

Area (RCA) to provide instruction for the proper removal of pivis;tive clothing at area step off pads, proper frisking guidelines and dosimetry  :

placement.

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Attach' ment 2

- RR9PONSE TO NOTICE OF VIOLATION

. (continued)

! 5. Senior Management has ' emphasized the use of the Radiological Work Practices Observadon Checklist as a method for reporting minor radiological work practice instances to provide a means for review and early identification

. of unfavorable trends.

6. Individuals identified as failing to follaw proper radiological work practices are being consted on the spot, and in appropriate cases, restricted from entry into the radiological controlled area until renwiintian is determined satisfactary, a.

7. The Training Department has completed an evaluation of its radiation worker training program and has instituted a more comprehensive approach to its practical factors testing by establishing more stringent pass / fail criteria (i.e.,

evaluation regarding proper frisking, wearing protective clothing, dosimetry placement and awareness of radiological conditions). Additionally, JAF has commenced benchmarking other utilities to assure our radiatius worker training program is challenging candidaten in practical factors testing.

8. For the three work practice ext.rnples referenced in the violation, a review of current radiation protection programs governing proper radiation worker performance standards was completed to identify opportunities to improve clarity, simplicity, consistency and availability of guidance to workers.

Improvements can be made and actions are in progress to publish simplified standards.

Results Achieved Rawd on radiation work practice observations following the implementation of the above actions, a general improvement trend has been achieved. Continued management oversight and reinforcement of standards are increasing worker awareness regarding proper radiological work practices.

Corrective Actions To Be Taken

1. Continue management oversight and reinforcement of standards to maintain worker awareness regarding proper radiological work practices.

2. A review of current radiation protection programs governing all radiation worker performance standards will be performed to identify activities where standards need to be improved. Improvements will clarify and simplify the' standards and assure their consistency and availability to workers.

Improvements will be incorporated into training as epinup; ate.

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Attachment 2

. RFSPONSE TO NOTICE OF VIOLATION

, (continued)

3. JAF will perform an assessment of radiation worker performance following l completion of its present refueling outage. The need for additional corrective 1 action will be determined following reviews of the assessments findings.

Date When Full Comoliance Will Be Achieved l The performance standards b ; good radiological work practices are being reinforced. Self identification of poor work practices is ongoing with enforcement of performance standards.

The number of poor work practice observations are decreasing and are immediately corrected. Full compliance will be achieved by June 1,1995 following neeeeement of ,

performance and incorporation of any additional corrective actions found in the post outage i assessment.

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• Attachment 3

. RFRPONSE TO NOTICE OF VIOLATION  ;

. Commitment Status JAFP-95-0028 Number Commitment Due Date JAFP-95-0028-01 A review of current radiation protection programs 3/14/95 governing all radiation worker performance standards will be performed to identify activities where standards need to be improved. Improvements will clarify and simplify the standards anel assure their consistency and availability to ,

workers. Improvements will be incorporated into training as appropriate. ,

JAFP-95-0028-02 JAF will perform an assessment of radiation worker 6/1/95 performance following completion of its present refueling outzge. The need for additional corrective action will be determined following reviews of the assessments findings.

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