IR 05000333/1986017
| ML20213G848 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/07/1986 |
| From: | Kaminski M, Lequia D, Shanbaky M, Tuccinardi T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20213G838 | List: |
| References | |
| 50-333-86-17, NUDOCS 8611180369 | |
| Download: ML20213G848 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-333/86-17 Docket No.
50-333 License No. DPR-59 Priority
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Category C
Licensee:
Power Authority of the State of New York P. O. Box 41 Lycoming, New York 13093 Facility Name: James A. FitzPatrick Inspection At:
Scriba, New York Inspection Conducted:
Septepber 29-October 3, 1986 Inspectors:
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7er M. Kaminski, Radiation Specialist date Approved by:
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M. S'hanbaky, Chief,
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Facilities Radiation Section Inspection Summary:
Inspection on September 29-October 3,1986 (Inspection Report No. 50-333/86-17).
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Areas Inspected: A routine, unannounced safety inspection by region based inspectors was performed of the licensee's radiation protection program. Areas examined included: internal exposure control, external exposure control, ALARA, and audits and appraisals.
Results:
No violations or deviations were identified.
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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewed.
1.1 Licensee Personnel
- R. Converse, Resident Manager
- W. Fernandez, Superintendent of Power
- D. Lindsey, Operations Superintendent
- R. Patch, Quality Assurance Superintendent
- E. Mulcahey, Radiological & Environmental Services Superintendent
- A. McKeen, Assistant Radiological Service Superintendent
- C. Gannon, Health Physics General Supervisor
- G. Vargo, Radiological Engineer 1.2 NRC Personnel
- A. Luptak, Resident Inspector
- Attended the exit meeting on October 3, 1986.
2.
Purpose The purpose of this routine inspection was to review implementation of the licensee's radiological control program during a mini-outage for Control Rod Drive Unit (CRDU) maintenance. Areas inspected included:
Status of Previously Identified Items
ALARA Internal Exposure Control
External Exposure Control
Program Audits and Appraisals 3.
Status of Previously Identified Items 3.1 (0 pen) Followup Item (86-06-03): Develop New Calibration and Quality Control (QC) Methods The licensee has changed the TLD system calibration from a tolerance of 50% to a more restrictive tolerance of 30%. Administrative procedure PDP-7, " Dosimetry System Calibration and Quality Control Procedure," paragraph 5.3.7, Revision 2, was reviewed and found to contain the required change. Although, the new tolerance is more restrictive, further evaluation of this criterion and how it would be applied by the licensee will be performed during a future inspection.
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The licensee now places QC dosimeters in trays of TLD's for process-ing.
Batches of TLD's for processing contain 2% QC dosimeters randomly placed in the TLD trays.
Since the trays hold 50 TLD's an average of one TLD per tray is used for QC.
Regardless of the size of the batch, the minimum number of QC dosimeters is three QC dosi-meter per batch. Administrative procedure PDP-7, paragraph 5.8, Revision 2, was reviewed and found to contain the above change to TLD processing quality control.
3.2 (Closed) Followup Item (86-06-04)
Improve calibrator facility The environmental conditions at the irradiation facility are depen-dent on the ventilation system for the area. The ventilation system maintains temperatures in the area to between +40 F and +80 F.
The manufacturers of the electronic equipment to be used with the irradia-tor stipulates the permissible operating temperature for the equip-ment is between +50 F and +104 F.
Procedure RTP-53, "Victoreen Electrometer Model 500 Operation and Calibration" has been written to provide a calibration procedure for the equipment, and paragraph
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4.2.2 Revision 0 provides a precaution that the operating temperature for the electrometer is between 50 F and 104 F and electrometer use outside this temperature range is not permitted. The licensee has made available a thermometer and a barometer in the irradiation facility. They will be used to ensure the operating temperature stipulated in Procedure RTP-53 is not exceeded.
Correction factors for temperature and barometric pressure within the permitted ranges are calculated in step 4.7 of the same procedure.
The licensee has purchased an NBS traceable source for use in the calibration of the ionization chamber. The source is a Victoreen Model 550-5, Serial 1364.
During the course of the inspection, the procedure to determine the effect of scatter radiation within the TLD irradiation facility was reviewed. Additionally, the irradiation facility was toured. The procedure for the experiment appeared adequate to determine if the scatter characteristics within the irradiation facility present a problem. However, the experiment had not been performed at the time of the inspection. The results of the experiment will be reviewed in a future inspection (50-333/86-17-01).
Based on this review, item 50-333/86-06-04 is close o
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4.0 ALARA The inspector reviewed the adequacy, effectiveness and implementation of the licensee's ALARA program with respect to criteria contained in the following:
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10 CFR 20.1, " Purpose";
Regulatory Guide 8.8, "Information Relevant to Ensuring the Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable "(ALARA);
Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable";
Licensee Procedures:
REP-1 "ALARA Review";
REP-4 " Selection and Use of Temporary Shielding";
Radiation Protection Manual " ALARA Program", Chapter 9 Evaluation of the licensee's performance in the area was based on the following:
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Discussions with cognizant personnel
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l Review of applicable procedures Review of the Monthly ALARA Report for August 1986.
Review of exposure tracking graphs for 1985 and 1986
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Review of the 1985 Annual ALARA Report, as presented at ALARA Committee Meeting No. 86-01 Independent tours of the Reactor Building, Drywell and Turbine Building
Review of ALARA estimates and work area setup for Control Rod Drive Unit Maintenance
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The licensee has estabitshed an adequate ALARA Program.
Program elements include Radiological Engineers who perform pre-job estimates and post-job reviews; and ALARA technicians who perform pre-job ALARA setup verifi-cation, and on-the-job review as work progresses. Appropriate equipment, such as: closed circuit television, radio headsets, portable water shields, integrating / alarming dosimeters and portable lead shielding systems have been purchased and are effectively used in support of the exposure reduction program. The licensee's application of these program elements to Control Rod Drive Unit (CRDU) removal and replacement activi-ties has reduced exposure from the previous 2000 mrem per CRDU to the current 1100 mrem per CRDU.
For 1985, a refueling year, the licensee had established an exposure goal of 1000 man-Rem. Actual exposure for that year was 1051 man-Rem.
For 1986 a non-refueling year, the established goal is 600 man-Rem.
This goal, however, does not appear to be challenging in view of the following:
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The licensee estimated that they would only need 575 man-Rem for the year.
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Exposure status as of September 14, 1986, was 248 man-Rem, with the potential for not exceeding 400 man-Rem for the year.
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NUREG-0713, " Occupational Radiation Exposure at Commercial Nuclear Power Reactors 1983 identifies the median exposure for all BWR's from 1973-1983, as approximately 650 man-Rem, which includes refueling outage.
While the licensee appears to effectively control exposure, as evidenced by the current exposure total, it does not appear that the 1986 goal serves as a useful management tool for exposure control.
The inspector discussed goal setting with the licensee, who agreed that the 1986 goal was "not ambitious enough" and that efforts would be made to improve the setting of future ALARA goals.
5.0 Internal Exposure Control The licensee's air sampling program, respiratory protection program and personnel frisking practice were reviewed against criteria contained in:
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10 CFR 20.103, " Exposure of Individuals to Concentrations of Radio-active Materials in Air in Restricted Areas."
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- Radiation Protection Procedures:
RTP-40, " Maintenance of MSA Respirators"
RTP-41, " Maintenance of Scott Respirators"
RPOP-4, " Radiation Work Permit Procedure" RPOP-6, " Respiratory Protection Procedure"
RPOP-12, " Inspection and Quality Assurance of Respiratory Protection Equipment" RPOP-11 " Posting and Control of Areas Containing Radiological Hazards RP02 "Pcesonnel Decontamination" The licensee's performance relative to these criteria was determined from:
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Tours of the Reactor Building, Drywell and Turbine Building to observe posting and respirator usage practices
Discussions with cognizant personnel
Observation of personnel frisking and decontamination practices Review of applicable documentation Review of air sampling records
A tour of the respirator maintenance facility Inspection of air sampling equipment Within the scope of this review, no violations were observed. The licen-see has an effective program for the selection, issue and use of respira-tory equipment. A modern facility has been established for the cleaning, maintenance and inspection of these devices. Suitable air samples were being collected and analyzed to support the respiratory protection program.
However, the inspector noted some weaknesses in the licensee's practices for personnel monitoring, specifically:
Several frisking booths in the Reactor Building had been established in areas with high background (650-2250 cpm), necessitating that the frisker be set on the X10 scale. This made effective frisking almost impossible. The inspector discussed this program weakness with licensee's management.
The licensee corrected the problem by discontinuing use of existing frisking booths, and assembling a new frisking booth in the low background of the track access are p
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Personnel exiting the drywell were observed performing a frisk in less than thirty seconds
Hand and foot frisks were frequently performed in less than five
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seconds
No calibration or operation procedure had been developed for the portal monitors even though they had been in use for several years.
The inspector discussed these items with the licensee, who stated that the portal monitors were only backup checks for the friskers and, therefore, did not require any type of procedure.
The inspector indicated to the licensee that the portal monitors had become a primary means of detecting personnel contamination due to the lax personnel frisking practices at the station. The licensee indicated that efforts to improve this area were underway, and that replacement of the portal monitors with automatic whole body frisking devices was being evaluated to strengthen this area of the program. This area will be reviewed in a subsequent inspection (50-333/86-17-02).
6.0 External Exposure Control i
The licensee's instrument control program, dose rate survey practices, and records were reviewed against criteria contained in the following:
10 CFR 20.201 " Surveys"
10 CFR 20.203 " Caution signs, labels, signals and controls" ANSI-N323-1978 "American National Standard Radiation Protection Instrumentation Test and Calibration" Radiation Protection Procedures:
RTP-4, "Teletector Operation and Calibration"
RTP-19, "Eberline Model R0-5A/D Operation and Calibration"
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RPOP-5, " Plant Radiation / Contamination Surveillance Program"
RPOP-4, " Radiation Work Permit Procedure" RPOP-11, " Posting and Control of Areas Containing Radiological Hazards"
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Licensee performance relative to these criteria was determined from:
Tours of the survey instrument calibration facility
Review of dose rate instrument calibration certificates and records
Observation of instrument source response checks
Review of survey records
Review of Radiation Work Permits (RWP) for Control Rod Drive Unit (CRDU) Maintenance
Tours of this radiologically controlled area to verify posting practices and control of high radiation areas.
- Independent surveys to verify dose rates Within the scope of this review, no violations were noted.
Licensee survey maps were significantly improved from previous inspections.
RWPs and survey maps for CRDU maintenance activities were adequately detailed and legible. Areas within the radiologically controlled zone were appro-priately posted and high radiation areas were controlled to prevent-unnecessary exposure.
However, the inspector did note some weaknesses in the instrument control program, specifically:
Issuance and return controls for survey meters are weak due to incomplete records A method to separate in-service from out-of-service instruments has not been established
Availability of instruments is limited. Over 50% (19 of 35 Victoreen 740-F and 30 of 42 Eberline R0-5a) of the licensee's primary dose rate survey instruments were out-of-service.
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The licensee's calibrator has been out-of-service for approximately nine months.
This has created a back log of instruments requiring calibration and makes it impossible to response check teletectors as required by RTP-4.
Review of calibration certificates for the R0-5A's identified 10 instruments past their calibration due date, yet potentially still in service.
Upon identifying this to the licensee, they were able to
" find" 9 of the 10 instruments, leaving one instrument potentially in
use.
- The source used to response check survey instruments prior to issue does not allow the checking of all scales.
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- The inspector discussed these weaknesses with the licensee, who stated that a vendor has been contracted to provide calibration services for doserate instruments, but that the turn-around time has added to the backlog of out-cf-service instruments.
To improve this area, the licensee is evaluating the purchase of a new calibrator to replace their broken unit.
In addition, the licensee committed to having an instrument issue and return area, with appropriate administrative controls, in service by June 1, 1987.
This area will be reviewed in a subsequent inspection (50-333/86-17-3).
The following additional areas were reviewed during the course of this inspection.
- The recent replacement of the UD801 TLD system with the UD812 TLD System. The transition from the old to the new TLD system was without incident, and did not adversely impact the current outage.
- Exposure summaries for the last quarter were reviewed for anomalous data. No persons were noted with exposures greater than quarterly
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limits.
Three persons having accumulated quarterly exposure in excess of 1.25 Rem were randomly chosen from the exposure summary.
Completed NRC-4 forms were requested for the three persons.
These forms were reviewed for compliance with regulatory requirements and found to be in order.
Within the scope of this review, no violations were identified.
7.0 Audits and Appraisals The implementations of the licensee's audit program was reviewed against criteria contained in the followup documents.
- 10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plant," Criteria XVIII, " Audits".
- Regulatory Guide 1.146, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants"
ANSI /ASME N45.2.23, 1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants"
Quality Assurance Procedure 18.1. " Audits".
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The licensee's performance relative to these criteria was determined during a review of the following audits and appraisals.
Appraisal JAF86-01, " Radiological / Environmental Program:
Audit SA86-04, " Radiological Incident Reports";
Audit 572, " Radiological and Environmental Services";
Audit 570, " Respiratory Protection Training";
Audit 476, " Personnel Monitoring";
Surveillance Report 1067, " Radiological Survey Techniques" The licensee audits are of two basic types.
Corporate audits are per-formed of major programmatic areas and are of sufficient depth to ensure requirements are implemented, and to determine adequacy of procedures governing the implementation of specific programs.
The second type of
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audit is called standard audit.
Standard audits are performed by corporate personnel located at J. A. FitzPatrick Station (FS). Generally, standard audits are of defined scope. The inspector noted these audits are of limited depth.
The limited depth of the HP standard audits was due to lack of audit persons specifically trained in health physics and chemistry. The inspector was informed by station management that there are three persons trained in health physics and chemistry located at the Corporate Offices in White Plains, New York. These three persons have recently been made available for the FS Standard audits.
The inspector was assured that this additional expertise would be utilized to provide greater depth to FS standard audits. This area will be reviewed in a future inspection (50-333/86-17-04).
Within the scope of this review, no violations were identified.
8.0 Exit Interview The inspectors met with licensee representatives (denoted in Section 1) at the conclusion of the inspection. The inspectors summarized the purpose, scope and findings of the inspection.