ML20205Q639
| ML20205Q639 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 03/19/1987 |
| From: | Loch E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8704030592 | |
| Download: ML20205Q639 (4) | |
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0 ff C0fp0 fall 0I1 Drawer R Columbia South Carchna 29250 1803)776 2610 March 19, 1987 U.
S. Nuclear Regulatory Commission ATTN:
Mr. J.
Philip Stohr, Director Division of Radiation Safety and Safeguards Region II 101 Marietta Street, N. W.
Atlanta, Georgia 30323 Gentlemen:
RE:
NRC Report No. 70-1151/87-02 Pursuant to the provisions delineated in Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, Westinghouse herein provides, in Appendix A, formal response to your letter of February 18, 1987, regarding your inspection of our facilities conducted during the period January 26-30, 1987.
In the above referenced letter, you stated that this violation was similar to a previous violation received in September 1986.
Westinghouse likewise is concerned about these types of violations and have performed an evaluation to identify the root cause of this problem.
As a result of our evaluation, we have concluded that certain personnel routinely using the change rooms and step-off pads assume that they are not contaminated following showering and washing respectively based upon past experience, and subsequently develop poor monitoring practices.
However, Health Physics monitoring of personnel exiting change rooms and step-off pads (and surveillance of these areas) confirm the effectiveness of personnel decontamination techniques.
In the past, we have addressed this problem by training personnel and streamlining the frisking procedure to facilitate monitoring.
Since these corrective actions have not been completely successful, I have implemented a comprehensive audit program of personnel exiting change rooms and step-off pads and have informed all Columbia Plant personnel that failure to properly monitor will result in disciplinary actions.
Details of these corrective actions are contained in Appendix A to this letter.
Since this management enforcement letter and audit schedule were issued, compliance with frisking procedures has been significantly improved.
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- 4 Page 2 March 19, 1987 Should you have any questions or require additional information, please telephone me at (803) 776-2610.
I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief.
Sincerely, Westinghouse Electric Corporation i
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Loch,.M nager Columbia Plant lb i
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- b APPENDIX A WESTINGHOUSE RESPONSE TO NRC NOTICE OF VIOLATION Violation 87-02-01 (1)
Admission or denial of the violation:
The violation is correct as stated in your Notice of violation.
(2)
The reason for the violation if admitted:
As a result of our evaluation, we have concluded that personnel routinely using the change rooms and step-off pads assume that they are not contaminated following showering and washing respectively based upon past experience, and subsequently develop poor monitoring practices.
Furthermore, we believe that some individuals require frequent reminders of the need for 100% compliance with procedures and policies when performing routine duties such as monitoring.
However, Health Physics monitoring of personnel exiting change rooms and step-off pads (and surveillance of these areas) confirm the effectiveness of personnel decontamination techniques.
(3)
The corrective steps which have been taken and the results achieved:
A letter dated February 11, 1987 was issued from the-Columbia Plant Manager to all Columbia Plant employes emphasizing the following:
j a) summarizing the violation, l
b) requiring strict compliance with washing and frisking requirements, c) requiring enforcement of change room and step-off pad requirements, d) requiring that contractors and vendors receive appro-priate frisking instructions, and e) notifying personnel that audit schedules have been established to monitor for compliance.
A letter was also issued February 11, 1987 from the Columbia Plant Manager establishing an audit schedule for change rooms and step-off pads to monitor compliance with frisking procedures.
The audits require:
a) monitoring to assure that proper frisking procedures are performed, b) reinstructing personnel as applicable in the proper frisking procedure, and c) forwarding audit results to management for individuals 4
w Page 2 March 19, 1987 not following frisking procedures.
This increased management attention and visibility has resulted in almost 100% compliance with frisking procedures.
The minor violations which have occurred have been referred to management for further action.
(4)
The corrective steps which will be taken to avoid further f
violations:
Evaluations are underway to determine whether additional efforts are necessary to facilitate compliance with frisking procedures including:
a) reducing the number of exit points from the contamina-tion controlled area, b) installing electronic surveillance at some exit points, and c) reviewing the adequacy of exiting frisking instrumenta-tion, including simplifying the frisking procedures.
These evaluations will be completed and a report submitted to the Regulatory Compliance Committee for review by May 1, 1987.
(5)
The date when full compliance will be achieved:
Full compliance has been achieved.
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