IR 05000333/1987006
| ML20209D614 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/20/1987 |
| From: | Lequia D, Loesch R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20209D582 | List: |
| References | |
| 50-333-87-06, 50-333-87-6, NUDOCS 8704290328 | |
| Preceding documents: |
|
| Download: ML20209D614 (10) | |
Text
.
f.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-333/87-06 Docket No.
50-333 License No.
DPR-59 Priority
-
Category C
Licensee:
Power Authority of the State of New York P. O. Box 41 Lycoming, New York 13093 Facility Name:
James A. FitzPatrick Nuclear Power Plant Inspection At:
Scriba, New York Inspection Conducted:
March 16-20, 1987 Inspectors:
MN[-
d 7h7/E7 D. P. LeQuia, Radiation Specialist
date Nf2 Y W/7l37
-
R. M. Loesch, Radiation Specialist date j
Approved by:
M, N /
M
M. Shanbaky, Chief, Facilities 1adiation dath
Protection Section i
Inspection Summary:
Areas Inspected:
Routine, unannounced inspection of the licensee's Radio-logical Controls Program during an outage.
The following areas were reviewed:
ALARA, internal and external exposure controls, radiation and contaminated material control, audits and appraisals and the instrument control program.
Results:
Three violations were identified (1 - Failure to audit qualifications of RES supervision, T.S. 6.5.2.8; 2 - Failure to follow RWP requirements, T.S.
6.11; 3 - Failure to adequately control high radiation area keys, T.S. 6.8).
The licensee was found to have made significant improvements to their radio-logical instrument control program.
,
8704290328 870420
!
PDR ADOCK 05000333 G
. _ -
-
_
_
-
-_
-
_ - _. _
, _ _ _ _ _ _ _.. _, _. _
.
,
DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel Ouring the course of this inspection, the following personnel were contacted or interviewed:
- R. Converse, Resident Manager
.
- W. Fernandez, Superintendent of Power
- E. Mulcahey, Radiological and Environmental Services Superintendent
- D. Lindsey, Operations Superintendent
- R. Patch, Quality Assurance Superintendent
- V. Walz, Technical Services Superintendent
- R. Baker, Maintenance Superintendent
- R. Wiese, Assistant Maintenance Superintendent
- G. Vargo, Radiological Engineer
- J. Solini, Health Physics General Supervisor
- J. Simplicio, Radiological Specialist, WP0 Other licensee or contractor personnel were also contacted.
1.2 NRC Personnel
- A. Luptak, Senior Resident Inspector
- Denotes attendance at the Exit Meeting held on March 20, 1987.
2.0 Purpose The purpose of this routine inspection was to review implementation of the licensee's radiological control program relative to the current refueling outage. Areas inspected included:
Status of Previously Identified Items Internal and External Exposure Control Audits and Appraisals
ALARA Radiological Instrument Control Program 3.0 Status of Previously Identified Items 3.1 (Closed) Follow-up Item (50-333/85-30-01):
Licensee to complete calibration procedures for all instrumentation in use.
Previous inspections had closed out all instruments with the exception of those addressed by procedures RTP-4, RTP-14, and RTP-44. The inspector noted upon review of Revision 1 of the previously men-tioned procedures that the licensee has addressed the areas of
.
.
calibration and linearity checks in these revised procedures.
Based upon these findings, this item is closed.
3.2 (Closed) Follow-up Item (50-333/86-17-01):
Licensee to determine scatter characteristics within the irradiation facility.
Inspector review of memorandums JRES-86-374 (Nov.1986) and JRES-87-006
,
(Jan. 1987), and discussions with cognizant personnel determined that
'
irradiator backscatter characteristics were evaluated by the licensee.
Based upon the results of the test, the backscatter contribution was determined to be 2.17 percent and does not represent a significant difference in the response of shallow (E1) versus deep (E3, E4)
element dose. Based upon these findings, this item is closed.
4.0 Internal / External Exposure Control The licensee's program relative to internal and external exposure control
,
was reviewed against criteria contained in the following:
'
Technical Specification 6.11, " Radiation Protection Program" Technical specification 6.8, " Procedures" 10 CFR 20, " Standards for Protection Against Radiation"
Operations Department Standing Order No.19, Rev. 4, " Procedure for Control of Non-Security Related Keys Issued to the Operations Department"
Licensee procedures:
RPOP-4, " Radiation Work Permits"
-
-
RPOP-9, " Radiological Survey Techniques" Licensee performance relative to these criteria was evaluated by the following:
Review of air sample records and associated MPC logs
Discussions with cognizant personnel
Review of outage Radiation Work Permits
Inspection of ALARA Review Packages
Audit of the High Radiation Area Key Control Box by the inspector
Independent surveys by the inspector
Tours of the Reactor and Turbine Buildings Review of documents from Operations Surveillance Test No. F-ST-99A, dated 2/16/87 Review of the High Radiation Area Key Sign Out Log
Review of survey documents
Review of GE Evaluation EAS 28-0387, dated March 1987, relative to Lost Parts Analysis of Control Blade Roller
Review of Unusual Radiological Incident Reports
Review of the licensee's Radiation Pratection Manual, Chapter 6 Within the scope of this inspection, the following violations were identified:
_.
.
.
Technical Specification 6.8, " Procedures," requires, in part, that procedures be established, implemented, and maintained which meet the requirements and recommendations of Regulatory Guide 1.33, 1972.
Regu-latory Guide 1.33, 1972, recommends that procedures for restrictions and activities in high radiaticn areas be established.
Procedure No. 19, " Procedure for Control of Non-Security Related Keys Issued to the Operations Department," which controls issuance of individ-ual high radiation area access keys by shift supervision (SS), requires, in part, in section 7, that:
1) the on-coming Shift Supervisor reviews the key log prior to taking the shift to determine if any keys are out or missing; 2) the SS, or designated alternate, will initial the form, designating his approval for issuing the key; and 3) semi-annually, the Operations Superintendent or his designated alternate will perform an inventory of the non-security related keys using the non-security related
'
key list as a reference.
Inspector review of the key log on March 19, 1987, determined that the Shift Supervisor reviews were inadequate, since they failed to identify that a controlled key (R-49) was missing.
Inspector review of the key log sheets for March,1987, identified thirty-three (33) instances of failure by the Shift Supervisor, or his designated alternate, to initial Form 8.1 authorizing issue of High Radiation Area and other controlled keys.
Inspector review of the last semi-annual inventory (Surveillance No.
F-ST-99A, dated 2/16/87) found it to be inadequate. Specifically, only one of two required "X1" keys, that provide access to the Tip Room (which routinely has dose rates greater than 1000 mR/hr), was accounted for by the inventory. This deficiency was not recognized by the licensee even though it underwent three (3) levels of administrative review. Conse-quently, no corrective actions were taken.
Inspector audit of the key cabinet on March 19, 1987, found all required "X1" keys to be accounted for.
The above instances of failure to follow procedures constitute an apparent violation.
(50-333/87-06-01)
The above matters and their similarity to a previous violation, as noted in Inspection 85-12, were brought to the licensee's attention.
The licensee stated that lock R-49 would be re-cored and a new key issued.
In addition, they placed a note in the Shift Supervisor Night
'
.
Order Book to enhance awareness of the key issue requirements of Proce-dure 00S0-19. The licensee further stated that procedures in this area would be strengthened.
z-r-
,
m
-
-,
w n-
-
-r-m--
g m
v r=
- -_
_
.
-
_._ -
.
,
1 s
Technical Specification 6.11 requires, in part, that procedures for personnel radiation protection be prepared and adhered to and that these procedures be formulated to maintain radiation exposures received during operation and maintenance as far below the limits specified in 10 CFR 20 as practicable. They shall also include contamination control techniques.
Procedure RPOP-4, " Radiation Work Permit," requires, in part, in section
,
4.9.3.d, that the leadman ensures that personnel working on the RWP comply with all dosimetry and protective clothing requirements.
RWP No. 87-345-S, dated 1/17/87, required plastic suits be worn "as per
HP."
The HP Technicians covering the job stated that, as a minimum, plastic bottoms were required for entry into the Reactor Refueling Cavity.
At about 0600 on 1/17/87, the leadman for RWP 87-345-S did not ensure that all personnel complied with the RWP. One individual, signed-in on the RWP, and performed work in the cavity, failed to wear required protective plastic suit bottoms.
The worker was subsequently contaminated.
'
ll This is an apparent violation (50-333/87-06-02).
,
I Within the scope of this review, the following additional matters were discussed with the licensee:
Inspector review of RWPs found that the phrase "as per HP" was i
frequently used to allow flexibility of radiological controls on the job. However, this practice makes it difficult to reconstruct what clothing or equipment was required or actually used-for a specific activity.
Frequently, the licensee is dependent upon the recall capability of the technician covering the job to determine what clothing or equipment had been used.
Lack of RWP specificity may lead to confusion and inconsistencies in implementing radiological controls.
The inspector discussed this weakness with the licensee, who stated that they had some awareness of the problem and would evaluate methods to improve this area.
Inspector tours of the facility found multiple instances where radio-active material containers were not labeled " CAUTION - Radioactive Material." Surveys of these containers indicated that 10 CFR 20,
Appendix C quantities were not exceeded.
However, the licensee took timely action to ensure labeling of the containers as a precautionary measure.
The inspector discussed this matter with the licensee who stated that they would evaluate methods to strengthen control in this area.
- Procedure 00S0-19 and the Radiation Protection Manual, Chapter 6, address the methods by which a key is issued to access a High Radi-ation Area. However, neither of these references specify what actions must be taken if a key is lost.
The inspector discussed
this matter with the licensee, who stated they would take action to improve this area.
- - - - - - -
-, -
_-- -,, - - - --
.
,. - - - -
,
,
l 5.0 Audits and Appraisals The licensee's program for Audit and Appraisal of the Radiation Protection Program was reviewed against criteria contained in the following:
Technical Specification 6.5.2.8, " Audits" 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" ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant
Personnel" Performance relative to these criteria was evaluated by:
Review of Safety Review Committee Procedure SRCP-9, Rev. 4, " Audits"
Review of Safety Review Committee Procedure SRCP-18.1, Rev. 3, "SRC Delegation of Audit Functions"
Review of Appraisal Report [[::JAF-86-01|JAF-86-01]], " Radiological Environmental Program" Review of the following Standard Audits:
-
No. 519
-
No. 521 No. 585
-
-
No. 614
Review of Surveillance Report Audit No. 1139, " Plant Organization /
Staff Qualifications" Within the scope of this review, the following violation was identified:
Technical Specification 6.5.2.8, " Audits," states, in part, that audits of the performance, training and qualifications of the entire facility staff shall be performed at least once per 12 months.
Procedure SRCP-9 further defines " entire" facility staff to mean those facility managerial, supervisory and operational personnel having responsibility for and exercising those functions required to assure the conformance of the facility operation to provisions contained within the Technical Specifications and applicable License Conditions.
,
.
- -,
,
_. _ - - _.... ~, -,..,
. _ _ _ _.. _. -,,.. _ _ _ _,, - _
, - -.
..,-.,,.,---__._-.m-
.,-.
.
. _. _ - _.. -
- -. = -
_ _ -
-
. _.
.
.
- _-.
..
,
<
Audits of personnel qualifications, for audit years 1983-1986, did not include evaluations of qualifications for Radiation and Environmental Services (RES) supervisors below the RES Superintendent (RPM).
This is an apparent violation (50-333/87-06-03).
The licensee, upon notification of the above apparent violation, took timely and aggressive action to audit the qualifications of RES Department supervisory personnel below the RES Superintendent. Subsequent to this inspection, a copy of this audit (No. 614, dated 3/23/87) was provided to the inspector on 3/25/87.
'
The following additional weaknesses in the licensee's Audit and Appraisal Program were identified:
Standard Audits were being performed on a periodic basis. However, inspector review of these audits found that audit personnel occa-sionally lacked the technical expertise necessary to properly evaluate the technical competency of radiological procedures.
Furthermore, the scope of these audits consisted mainly of pro-cedural compliance. Therefore, these audits were spot-checks only and not programmatic reviews of the implementation and quality of Radiation Protection Program.
- Inspection Report 86-17 had also identified the above weakness.
.
To correct this weakness, the licensee had stated that Corporate Appraisal staff personnel would be used to augment the techni.11 qualifications of the Quality Assurance (QA) Group during Star, rd Audits. However, the recent loss of a Senior Appraisal Specialist -
Radiological from the Appraisal Group weakens their ability to pro-vide technical support for Standard Audits.
The licensee is actively seeking a replacement for this position.
The inspector discussed the above weaknesses and the apparent violation
.
with the licensee. The licensee stated that the following corrective actions would be taken:
,
To develop a detailed audit plan for the Radiation Prctection Audit Program.
- To audit this plan on a two (2) year basis.
- To evaluate the need for audit technical assistance on a case-by-case basis.
- To focus the audit program on implementation and effectiveness of the established Radiation Protection Program.
To conduct an audit of the qualifications of the RES Supervisory
!
staff below the RES Superintendent (RPM) and to review changes to
'
the RES staff on a 12 month basis, i
,
- - -
-. -
.-
~. -
. -
_-
..
,
_
.
.-.
. - - _ _ - _. ~
..
-
. -
..
8
6.0 ALARA
'
The inspector reviewed the adequacy, effectiveness and implementation of the licensee's ALARA program with respect to criteria contained in the following:
,
10 CFR 20.1, " Purpose"
Regulatory Guide 8.8, "Information Relevant to Ensuring the Occupa-tional Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" (ALARA)
Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupa-tional Radiation Exposures As Low As Is Reasanably Achievable"
,
Licensee Procedure REP-1, Revision 4, "ALARA Review" The evaluation of the licensee's performance in this area was based upon the following:
Discussions with cognizant personnel l
Review of exposure tracking graphs
Evaluation of ALARA Review packages and associated Radiation Work Permits (RWP)
Review of 1987 ALARA goals Review of shielding evaluations
Attending a Plant ALARA Committee Meeting
Independent tours and surveys of the Restricted Area The licensee has implemented and continues to strengthen their ALARA program. This program includes pre-job, on-the-job and post-job evalu-ations of activities to control exposure.
Inspector review found that appropriate procedures were in place to control ALARA work retivities and that additional equipment has been purchased in support of the program. This includes a mock-up of a recirculation pump seal package.
,
An exposure goal of 950 man-rem has been established for 1987. This goal has been subdivided into 700 man-rem for the current refueling outage and
-
250 man-rem for the remaining coerational year.
Inspector review of
exposure tracking graphs revealed a close correlation between estimated and actual exposure thus far into the outage.
During inspector review of ALARA packages, it was noted that, while the package contained valuable information from previous experience, this
information was not always effectively utilized in preparing subsequent
-
ALARA Reviews. The inspector discussed this with the licensee who stated they would evaluate appropriate methodology to ensure effective use of available data.
Within the scope of this inspection, no violations were noted.
!
,
-
,,.
_,
, _. - _ -. _... _ - -.
, _ - _ _ - - _.. _ _. - _. _ _, ~ _..,..... _, _. _
.
-
,,. _ _.
_ _ _ _, _ _,. -,
-
.
.
.
7.0 Radiological Instrument Control Program The licensee's Instrument Control Program was reviewed against criteria contained in the following:
ANSI N323-1978, "American National Standard Radiation Protection Instrumentation Test and Calibration"
Radiation Protection Procedures:
RTP-4, "Teletector Operation and Calibration"
-
RTP-14, "Model 302B High Level Probe"
-
RTP-19, "Eberline Model R0-5A/D Operation and Calibration"
-
RTP-44, "3090 Alarming Gamma Monitor"
-
Performance relative to the above criteria were evaluated by:
Discussions with cognizant personnel
Review of calibration certificates
Review of Eberline Model 10008 calibration curves
Tours of the survey instrument calibration facility
Review of survey instrument inventory records, and
Review of survey instrument maintenance records Within the scope of this review, no violations were found.
Licensee instrument control practices were significantly improved from previous inspections.
Specifically:
A dedicated individual has been assigned to this area. This
-
provides better accountability and control of survey instruments.
Inspector review of survey records found them to be significantly
-
improved in detail and accuracy.
A method to separate in-service from out-of-service instruments
-
has been established.
An instrument issue area has been established to provide for the
-
effective control and issuance of instruments.
Inspector review of inventory records found improvement in the
-
number of instruments available for use.
The licensee's instrument calibrator has been returned to service.
-
.
.
8.0 Exit Meeting The inspector met with licensee management personnel at the conclusion of this inspection and discussed the findings of the inspection including apparent violations and program weaknesses.
.
-.
.
.-