05000333/FIN-2011009-03
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Finding | |
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| Title | Failure to maintain complete and accurate records as required by 10 CFR 50.9 and TS 5.4.1. |
| Description | 10 CFR 50.9 states, in part, that information required by statue or by the Commission\\\'s regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. The FitzPatrick Technical Specification Section 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained for the applicable procedures recommended in the RG 1.33, Appendix A (November 1972 edition). Appendix A, Section G of the RG identifies radiation protection procedures for control of radioactivity for limiting materials released to the environment and limiting personnel exposure. These include access control to radiation areas, contamination control, and personnel monitoring. Section H.2.b of the RG identifies radiation protection and surveillance tests that should be covered by written procedures. These include inspections and calibrations for each surveillance test, inspection, or calibration listed in the technical specifications. A. FitzPatrick procedure RP-RESP-04.09, Portacount Respirator Fit Testing, Revision 10, provides the requirements, procedure, and acceptance criteria for respirator fit testing. Section 3.2.1 states that the records generated by the performance of the procedure are considered quality records. Contrary to the above, on multiple, but an indeterminate number of occasions between 2006 and 2009, respirator fit testing records maintained by the licensee were not complete and accurate in all material respects in that the annual quantitative respirator fit test qualification records for several involved individuals indicated that the tests were performed, when in fact, the fit tests had not been conducted. B. FitzPatrick Procedure RP-RESP-03.01, Drywell Continuous Atmospheric Monitoring System, Revisions 18-27, provides instructions for operation and calibration of the DWCAM. It specifies that after valve manipulations, a second individual must verify correct valve position. Attachment 1 documents weekly data and requires initials and signatures for independent verification of valve manipulations performed during these checks. Contrary to the above, on at least 11 occasions between September 2007 and December 2009, DWCAM surveillance records maintained by the licensee were not complete and accurate in all material respects in that procedurally required signatures for independent verification of valve manipulation were either forged (two instances) or entered after work completion by personnel who did not actually perform the verifications (nine instances). These procedure records were material since they are identified by the licensee as quality records. |
| Site: | FitzPatrick  |
|---|---|
| Report | IR 05000333/2011009 Section 2RS1 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | TEV: Severity level III |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | W Dean A Defrancisco M Gray D Roberts D Holody K Farrar P Wilson J Lubinski C Miller E Monteith J Teator |
| Violation of: | Pending |
| INPO aspect | |
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Finding - FitzPatrick - IR 05000333/2011009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2011Q4
Self-Identified List (FitzPatrick)
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