ML20151V538
| ML20151V538 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/10/1998 |
| From: | Walter MacFarland ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-461-98-15, NUDOCS 9809140354 | |
| Download: ML20151V538 (5) | |
Text
lilinois Power Company Clinton Power Station P o Box 678 Clinton. IL 01727 Tel 217 935 5623 Fax 217 935 4632 Walter G. MacFarland IV Senior Vice President
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.ILLIN@lS P9WER An Illinova Company 9
September 10, 1998 Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Reply to Notice of Violation Contained in Inspection Report 50-461/98015 (DRS)
Dear Madam or Sir:
The purpose of this letter is to provide the Illinois Power (IP) response to the Notice of Violation (NOV) documented in NRC Inspection Report 50-461/98015 (DRS). IP admits that this violation occurred. In addition, aggressive action has and will continue to be taken to address issues associated with radiation worker adherence to radiation protection procedures.
The NOV identifies the failure of an individual to use a half man frisker (personal contamination monitor) when exiting the Radiological Controls Area as required by station procedures. Additionally, a concern regarding continuing problems associated with radiation protection procedural adherence was identified. Illinois Power has taken substantial actions to improve management oversight and accountability at CPS over the past several months. The response to this NOV and concerns regarding radiation protection procedural adherence is contained in Attachment A of this letter.
l IP believes that the actions described in the attached response address the concerns identified in this Notice of Violation.
Sincerely yours,
^
Walter G. MacFarland, IV Senior Vice President and Chief Nuclear Officer
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Attachments cc:
NRC Clinton Project Manager i
NRC Resident Office, V-690 Regional Administrator, Region III, USNRC j
Illinois Department of Nuclear Safety.
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Attachment A to U-603075
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j Page 1 of 3 Response to Notice of Violation 50-461/98015-01 i
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The violation states in part:
" Technical Specification 5.4.1 requires, in part, that written procedures be l
established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, February 1978, Sectio i 7(e) recommends j
that radiation protection procedures be implemented which cover personnel monitoring and contamination control.
Procedure CPS No. 1024.02, Revision 2, " Radiological Work Control,"
implements Technical Specification 5.4.1 by addressing personnel monitoring and contamination control. Section 2.1 of that procedure requires,in part, that prior to exiting the Radiological Control Area (RCA) utilizing any point other than the designated areas, an individual must obtain approval from a Radiological
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Operations Supervisor. Further, all personnel exiting the RCA must successfully l
pass through a " half man frisker" (a personal contamination monitor), or when authorized by radiological operations, monitor themselves by performing a manual whole body " frisk" (survey), or contact radiological operations personnel for i
i assistance.
Contray to the above, on January 19,1998, an individual exited the RCA utilizing a point other than the designated areas without obtaining approval from a Radiological Operations Supervisor. Furthermore, the individual failed to pass through a personal contamination monitor, failed to perform a whole body survey and did not contact radiological operations personnel for assistance."
Background and Reason for the Violation i
On January 19,1998, at approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />, Clinton Power Station (CPS) conducted a planned fire drill as ongoing training to ensure the operational readiness of the CPS fire brigade. The operations crew scheduled to participate in this drill had failed a l
previous drill conducted in December 1997, due to an untimely response. Prior to the fire drill, a pre-job brief was conducted on the standard rules for fire drills that included the requirement to follow all security and radiological protection requirements. When the fire drill started, members of the Fire Brigade responded to a fire brigade equipment storage cage, located inside the RCA, to don protective equipment including self contained breathing apparatuses (SCBAs). During the process of donning protective equipment, the Fire Brigade Leader (FBL) discovered that all of the SCB As had beer, taken. The shortage of SCBAs at this fire brigade equipment storage cage was attributed to extra Fire Brigade members who were participating in the drill in order to maintain their fire brigade qualification. The FBL decided to obtain a SCBA from another fire brigade equipment t
storage cage located outside the RCA. Upon approaching the RCA bounday, the FBL asked a Radiation Protection Technician (RPT) standing in the area if they were a RPT
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Attachment A to U-603075 Page 2 of 3 and then quickly exited the RCA without utilizing a half man frisker or receiving a response from the RPT. The FBL then obtained a SCBA from the fire brigade equipment I
storage cage located outside the RCA and returned to the drill location inside the RCA.
The RPT who witnessed the FBL exit the RCA without processing through a half man frisker as required notified the Radiation Protection Shift Supervisor (RPSS) of this act.
The RPSS directed the RPT to perform radiological surveys in the area outside the RCA j
that had been compromised by the FBL. The results of the survey detected no contamination above background. Upon completion of the fire drill, the RPSS restricted the FBL's access to the RCA and wrote Condition Report 1-98-01-242 to investigate and t
track this issue to resolution.
The reason for this violation was the FBL made a conscious decision to exit the RCA l
without properly processing through a half man frisker. A selfimposed time limit, l
associated with the drill, was the motivating influence in the decision to violate the l
established procedural requirements.
Corrective Step-Taken and Results Achieved i
A radiolcgical survey of the area outside the RCA compromised by the FBL exiting the
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RCA without processing through a half man frisker was performed. No activity above i
background was detected.
1 The FBL was counseled by the Assistant Plant Manager of Operations and the Assistant Director of Operations and appropriate disciplinary action was taken. Expectations concerning procedural compliance associated with radiation worker practices and the resulting consequences of this ewnt were also addressed with the FBL.
Corrective Steps to Avoid Further Violations In addition to the corrective actions stated, Illinois Power (IP) has taken other substantial actions to improve management oversight and accountability at CPS. These actions include adding a number of new members to the management team at CPS. In previous assignments, these individuals have shown a clear understanding of the importance of continuous improvement and striving for excellence.
Management Action Response Checklist (MARC) training has also been pwvided to managers, directors, supervisors, and group leaders to establish coaching and counseling practices to be used with their personnel. In addition, a Leadership Development Institute (LDI) course has been developed and is in progress. This is a three-week course for first line supervisors and a one-week course for middle and senior managers. This course includes a model for accountability that is used by CPS personnel to measure themselves against during the performance of assigned work.
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Attachment A to U-603075 l
Page 3 of 3 A program ofin-plant observation by management has also been implemented. This program includes a means of measuring behaviors and reinforcing the expectations of management regarding the standards of performance for work that minimizes human error.
l The purpose of this monitoring program is to improve performance by er.suring l
management awareness of the work force values, practices, and behaviors. This program also provides for feedback to the work force regarding management expectations.
l Personnel accountability for violating radiation worker performance has also been increased. Disciplinary guidelines have been put in place for violating access control requirements for signing in and out on Radiation Work Permits. Performance indicators for Radiation Worker events indicate an improving trend since the implementation of these corrective actions.
Date When Full Compliance Will Be Achieved Clinton Power Station is currently in full compliance with NRC-required radiation protection procedures.
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