IR 05000333/1997004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/97-04 Completed on 970525

ML20217P997
Person / Time
Site:	FitzPatrick
Issue date:	08/12/1997
From:	Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
50-333-97-04, 50-333-97-4, NUDOCS 9708290103
Download: ML20217P997 (3)

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3 August 12, 1997

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Mr. Michael Site Executive Officer New York Power Authority James A. FitzPatrick Nuclear Power Plant Post Office Box 41 Lycoming, NY 11093

Dear Mr. Colomb:

Subject: NRC inspection Report No. 50 333/97 04 and Notice of Violation This letter refers to your July 17,1997 correspondence, in response to our June 13,1997 letter.

' Sank you for informing us of the corrective and preventive actions documented in your letters. These actions will be examined during a future inspection of your licensed program.

Your cooperation witn us is appreciated.

Sincerely, Original Signed by:

John F. Rogge, Chlef Projects Branc,h 2 Division of Reactor Projects Docket No. 50 333 cc:

C. lapployea, Chaliman and Chief Executive Officer R. Schoenberger, President and Chief Operating Officer '

J. Knubel, Chief Nuclear Officer and Senior Vice President H. P. Salmon, Jr., Vice President of Nuclear Operations l W. Josiger, Vice President Engineering and Project Management

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j J. Kelly, Director Regulatory Affairs and Special Projects T. Dougherty, Vice President Nuclear Engineering R. Deasy, Vice President Appraisal and Compliance Services R. Patch, Director - Quality Assurance G. Goldstein, Assistant General Counsel lggg g 3333 C, Falson, Directur, Nuclear Licensing 145 P FL ".89 M *88 K. Peters, Licensing Manager T. Morra, Exocutive Chair, Four County Nuclear Safety Committee 9708,290103 970812 PDR ADOCK 05000333 G POR OFFICIAL RECORD COPY IE:01

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cc w/ copy of Licensee's Response Letter: '

Supervisor, Town of Scriba ,

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C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law P. Eddy, Director, Electric Division, Department of Public Service, State 1

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of New York G. T. Goering, Consultant, New York Power Authority  ;

J. E. Gagliardo, Concultant, New York Power Authority ,

E. S. Beckjord, Consultant, New York Power Authority i F. William Valentino, President, New York State Energy Research  ;

and Development Authority ,

J. Spath, Program Director, New York State Energy Research-and Development Authority

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Distribution w/ copy of Licensee's Response Letter: l RI EDO Coordinator l A.- Dromerick, NRR  :

K. Cotton, fJfM  !

D. Hood, NRR  !

M. Complon, RI R. Correla, NRR '

F. Talbot, NRR l Nuclear Safety information Center (NSIC) l PUBLIC  !

NRC Resident inspector ,

Region l Docket Room (with concurrences)  !

_I nspection Program Branch, NRR (IPAS) l J. Rogge, DRP  !

R. Barkley, DRP i R. Junod, DRP DOCDESK .

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DOCUMENT NAME: - A:\RL9704 FTZ To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment /eng4sure "N" = No copy -

OFFICE Rl/DRP ]/' ft/DRP NAME GHunegs Tejp4Rogge N DATE 08/h/97-- W/ 08/n/97

[ OFFICIAL RECORD COPY

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,9 Nuclost Qowe# Pterit u. t. e n.,

Po sos 41 Wcomeg. New York 13093 315 34z.3s40 M NewWrkPower u,,n,,, 3. c ,,,,

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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 Insoection Report 50 333/97-04 Daar 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 docum6nted in the Hun an 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.

Attachment 1 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 broeder implications of the violation and avoid further violations, and the date of full compliance.

There are no commitments contained in this report, if you have any questions, please contact Mr. Arthur Zaremba at (315) 349 6365.

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Very truly yours,

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d STATE OF NEW YORK MICHA J. COLOMB COUNTY OF OSWEGO MJC: RAP:las Subscribed and sworn to before me cc: next page this 11* day of Julw ,1997.

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cc: Regional AdministrClor

.I U.S. Nuclear Regulatory Commission 475 Allendale Road ,

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King of Prussia, PA 19406 Office of the Resident inspector U. S. Nuclear Regulatory Commission P.O. Box # 36 Lycoming, NY 13093 ,

Ms. K. Cotton, Acting Pro}ect Manager Project Directorate 11  ;

Division of Meactor Projects 1/11 U. S. Nuclear Regulatory Commission Mail Stop 1452 Washington, D.C. 20555 ,

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REPLY TO NOTICE OF VIOLATION NRC Inanection Renort 97 04 Violation i During an NMCinspection conducted from April t3 to May 25,1997, a violation of NMC requirements was identified. In accordance with the *GeneralStatement of Policy and Procedure for NMC Enforcement Actions,' NUMEG 1600, the violation is listed below:

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Technical Specification 6.11 requires, in part, that procedures for personnel radiation protection shall be prepared and adhered to for allplant operations. Administrative ,

Procedure (AP) 07.00 (Mev. 0), Mediation 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:

It) On December 7,1996, two radiation workers did not adhere to the radiation work permit, disregarded radiological posting requirements and one worker improperly used the portal monitor. These practices resulted in an individual becoming contaminated; and (2) On April 16,1997, in two sepaD 6%nts, radiation workers escorted three visitors into the plant cable tunne v&:1 a a radiologically controlled area (MCA).

The entrance to the cable tunnel w'a3 puentd with a yellow and magenta sign which stated ' Caution Madioactive Material * that the area was an MCA, that only authorizedpersonnel 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.

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This is a Severity levelIV violation (Supplement IV).

Admlanlon or Denial of the Alleged Violation The Authority agrees with this violation.

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Reasons for the Violation The cause for the violation was personnel error. The performance factors leading to these errors were:

- Personnel feited to accept personal responsibility to adhere to written and posted instrucalens reeutting in unauthorized access to radiological areas, in the first example, workersW to obtain a rt'diat!on protection briefing prior to entry into a contameneted area, in the second example, the workers failed to adhere to postings in that they entered ~a'tadiological area without required dosimetry for their escorted visitors.

- Personr.el f ailed to un eva% ile resources, the technical assistance of the radiation protection e=ff,'o perform the tasks appropriately.

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.' REPt.Y TO NOTICE OF VISLATl N NRC inanaction Renart 97 04

. 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 poper preparation, including failing to obtain ,,

radiological brlefings 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 baan Taken immediatalv followina the avant in examola 1:

The individual who alarmed the security portal monitor:

- The irdividual was decontaminated and interviewed. .

. Follow up contamination surveys were performed to ensure there was no further

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spread of contamination. .

- This individual was placed on radiological hold temporarily rescinding his authorization to access the RCA. " %c investigation of the improper use of the portal monitor, the individuel's employr, na JAF ended.

The second individual w, c not adhere to the radiation work permit was provided job

performance counseling.

Additional corrective actions taken for examola 1:

- Operating shift workers were presented radiological briefing expectations to assure utilization of radiation protection resources.

. Plant Mstf was informed of the event, the cause of the event, and the requirement to follow wristan and posted instructions.

Immediatahr P"-- di the avant in examola 2:

. Techniciarw 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 were in the area.

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REPt.Y TO NOTICE OF VIOLATION NMC lt-etion Renort 97 04

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. The escorts were placed on radiological hold temporarily rescinding their authorization for access into the RCA.

- The escorts were counseled by radiation protection personnel and their supervisors.

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- Second physical barriors were placed at RCA entrances to prevent recurrence of this type of event., Second barriors currently include radiation ropes or swing gates with signs, in addition to normal radiological postings.

- An tvaluation 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.

Additional corrective actions taken for examola 2:

. The individuals who inappropriately escorted visitors into the RCA were disciplined in accordance with Hurnan Resources policies.

- Plant personnel were immediately notified by memorandum of this particular incident

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description and radiological consequences.

figaulta Achieved The Authority believes the corrective actions taken were effective in preventing recurrence. The Fit Patrick 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 involvement through our Radiological Work Excellence Plan.

Cgractive Actions to Be Taken to Ura tand n the Brender Imnlications of Thana_Vlolations 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. Fit Patrick Nuclear Power Plant, a team of line personnel was formed and has evaluated human performance related events at the site. The corrective actione developed by the team are being implemented to ensure continued performance imptovement, in addition, The Radiological Work Excellence Plan was developed and issued May 21,

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1997. This plass le also focused on improving human performance. The actions are carried out by teams and involve radiation workers in many departments at Fit Patrick. The strategy of b 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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.* REPLY TO NOTICE OF VIOLATION fdRC inanaction Renort 57 04

Guidelinea 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.

Data When Fud Comnilance WIN Be Achieved Management expectations for improving human 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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