JAFP-87-0860, Forwards Response to Weaknesses Identified in Appraisal of Radiation Protection & Chemistry Program Insp 50-333/87-18. Exempt Position Description of Radiation Protection Supervisor Revised

Forwards Response to Weaknesses Identified in Appraisal of Radiation Protection & Chemistry Program Insp 50-333/87-18. Exempt Position Description of Radiation Protection Supervisor Revised

ML20236F430
Person / Time
Site:	FitzPatrick
Issue date:	10/26/1987
From:	Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
JAFP-87-0860, JAFP-87-860, NUDOCS 8711020136
Download: ML20236F430 (25)

Text

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M, Jimra A. Fit:Pdrick '

"' M Nuclxt Pow;r Pl. Int '

,. ,,_,, . PO. Box 41 . il q-( j Lycormng. New York 13093

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.y39' Radford J. Converse A NewYorkPower

& Authority- .

' October 26, 1987 f' JAFP-87-0860 '

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e g7 z United States Nuclear

{oh 4 'Regulatory Commission .

Attention- Document Control De d.

Washington, D.C..'20555

SUBJECT:

- JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET No. 50-333' INSPECTION 87-18 Gentlemen:

The subject- inspec tion ', : e.n appraisal of our radiation pro-

.tg.c. tion and chemistry programs at the J ame s - A . FitzPatrick Nuclear Power Plant, transmitted by your letter dated ' August 19,'1987, identified a number of strengths and weaknesses in this program. In response to your request. contained in the cover letter of this appraisal an attachment to this letter-  ;

transmits our response to the weaknesses identified in the j report. '

We appreciate the professionalism of your staff in the conduct of this appraisal >.

t, Should you have any questions regarding these matters, please c'ontact Eric A. Mulcabey of my staff.

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' ,W RADFORD J. CONVERSE RJC:GJV:EAM:emd CC: E. Mulcahey A. Luptak (USNRC)

T. Martin, Director DRES, Region I NRCI-87-18 (Fila)

Document Control Center, H.. WP0 Recoros Management f.% l

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~ NRC HEALTH PHYSICS 7 Ai?PRAISAL (INSPECTION 87t$17). "f kM APPENDIX A'- PROGRAMMATIC WEAKNESSES ,

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-FINDING:

1. 0. a '. V,p >.<, "t Excessive.over*1me work by the technicians is allowed. One tachnician worked a.. . 68. days consectItit%y ,ot ,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day. Overtime guidance of Plant

%.L StAiding Order No.' 0 26-f oifrequently waived. +s ..

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In planning for ' future outages, sufficient p e r s o n n e l v ,i l l b e '

'provided to assure that the - guidelines of Plant S tanuing Order; ./-

1. .. 26, " Overtime Policy" can be met. 6 Any waivers of ' the overtimb > ,, '

i A policy guidelines- will" be~ >juqAfied. and authorized on- an 1

1. e indL'vidual basis rathtr. than fot!/ the entire RES technician staff.

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m 'IFINDI G : 1.0.b 1 ,

4 A N LTedhnicians fand ffirst- line ; supernsors D are we'ak - in : the technical knowledge

.  : although ; technicians 1 rec'eive 4 " days e of training c every '6 . weeks and, training .

4 . < programs?are well controlled.

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" RESPONSE:1

?Asinoted.jan excellent' training program exists'and is exaect'ed to.

receive iaccreditation i from ' the nationalf academy in. Decemier .1987.

The - Authorityx believes' . that ..the training weaknesses n o t'e d . s t e m

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'from -the icurrent- needi to: ' train technicians . in both the Radi'ological 'and - Chemistry. _ disciplines because the. technicians:

. worko in both . fields . The .: Authority expects - to discontinue this -1

. practice in; the. near ' future. This will allow ^ technician training

~to be more focused' and effective.. . Supervisors will attend i

, Eselected portions.of'the technician ~ training program.

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-FINDING: 1. 0. c ~-

The position of " Senior Appraisal Specialist - Radiological" has been vacant'50%.

of the time since it was created in 1985.

RESPONSE

The nature . and structure of the appraisal function is currently under review by - senior Authority management as part of a larger ,

organizational re-evaluation and is scheduled for completion _by  !

-the end of'1987.

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' FINDING . 1.0.d !

The ' Exempti Position Descriptions for Assistant Emergency Plan' Coordinator and Radiation. Protection Supervisor are not recurate reflections of position responsi-

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-RESPONSE:

The exempt- position description for . Radiation ' Protection, Super-visor has been . revised. Personnel action' has been approved for  !

promoting the Assistant Emergency- Plan -Coordinator to Emergency Plan Coordinator. .!

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F i FINDING: 1.0.e I

' Insufficient numbers of' technicians during routine operations prevents' effective i cross-training or scheduling flexibility.

RESPONSE

Additional contract technicians have been provided for the 1988 l budget.

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FINDING: -1.0.f.

' RP. Supervisors are assigned' to ~areas where they have no training . or' prior experience.(e.g., respiratory protection).

RESPONSE

The LRadiation Protection Supervisor currently. assigned to the

' respiratory.. protection program has had extensive training and

- experience .in .this area.- A - reassignment of . Radiation Protection Supervisor responsibilities is in progress, however, due to a

.' misunderstanding, >it was implied that this reassignment was completed at-the time'of the appraisal before the. newly designated

.. supervisor. had received appropriate training -in respiratory-protection.

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' FINDING: 1.0.g The corporate " Tables of Organization" do not accur.ately reflect . the site

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RESPONSE

A' revision to the Corporate Table of' Organization has'been prepared- y 4

and submitted to the responsible' organization for inclusion in the 1988 revision of:this document.

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.. q FINDING: 1.0.h-Insufficient lead time was used when bringing the Corporate Radiological

.. Engineer on site to assist during outages.

RESPONSE

.This. weakne'ss was previously self-identified in an internal critique of. the 1987 refueling outage and ?will be corrected for

future outages.

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FINDINGS 2.0.a

A retraining. program developed specifically-for. supervisors.has not.been imple-mented.

-RESPONSE: )

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'y 'A corporate- training- program has been developed for supervj.sory ' skills . Technical' skills will be addressed by having supervisors attend . selected portions of the technicians training program.

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FINDING: . 2.0.b Training and qualification records are not' consolidated to allow verification'of-

,, _ ANSI' status.,

RESPONSE

The -Authority does not agree that this.is a weakness. . Adequate documentation . of . personnel training and_ qualification are maintained in.the Individual Training Files and Personnel Records.

The separation of' these records- is necessary to ensure adequate protection of personal data under the New York State Personal.

Privacy Act.

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-FINDING: 2.0.c Requirements are frequently waived. ,For example, staff technicians are waived from~certain requirements:of Apprentice program and ex-Navy ELT are granted ANSI status, i

RESPONSE

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The Authority does not consider the practice of granting credit for-prior training to.be-a weakness. Detailed procedures for grant-ing {

such credit are contained in Corporate Training Procedures. These' i procedures' require-that records of satisfactory program completion ,

be examined and incorporated into Individual Training Files ~ prior j' to granting credit.

The.Unfvecsity'of the State of New York ha's evaluated the U.S. Navy i Nuclear Power School and granted 32 semester hours of academic credit. @ere ' appropriate, advance' standing in the technician 1 training program is ' granted for ' subjects such as basic courses in: {

mathematics, thermodynamics, chemistry fundamentals, classical physics and electricity. Some credit is granted for specific '

topics such as corrosion, water purification, sampling techniques  ;

.and basic radiation' detection and interaction of -radiation with a matters however,. such waivers are applied conservatively. For j example, credit. .is not given for subjects such as airborne '

radioactivity -and contamination control, areas infrequently encountered-in the naval nuclear power program.

1 ANSI qualification is granted only for those ELTs who served in a 1 lead capacity and have completed applicable portions of the RES Technician Qualification Standard.

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.n FINDING: 3.0.a

, No program has been developed to identify and control " hot particles." The skin

' dose assessment procedure for hot particles was incomplete.

' RESPONSEi

'Many elements of a hot particle control program were in glace at the time- of the appraisal. Procedure RPOP-2, "Personne:. Decon-tamination", was revised to address hot particles and dose assess- 1~

- ment prior to the appraisal. Procedure PDP-11, " Dose Assessment of< Personnel Contamination Incidents" was approved as a procedure

- under . development prior to the appraisal. Refinements to this

- procedure are in progress 'and will 'be completed by . November 30, _;

1987. High-sensitivity portal monitors to aid in the-detection of hot particlesLhave been purchased, installed . and ~ are . in ' operation' at exit points from the restricted area. These units were on-site

at the time of'the appraisal and subsequently have:been:placed in; service. Interim engineering controls for hot particles'.have been

. developed and are being implemented for. work on thos'e plant. .

systems that ' are identified as having - a high potential for hot i particle contamination.- These interim control measures will .. be  ;

replaced by specific precautions.in maintenance procedures through the biennial review process. H

' The staff is . continuing to evaluate .variour ' methods of improved , !.

surveillance and' detection of hot particles. l 1

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FINDING: ' 3. 0.b . .

No3 program .has' been , deyeloped for the collection and analysis . of 'in-vitro

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-samples to evaluate intakes which .cannot be quantified by in-vivo z whole body'

counting.. .

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complete by December 31, 1987. .This was--; identified previously by 3 the' plant staff as a program that required upgrading.  !

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' Management - hasl, not been aggressive' in; implementing l a chemistry organization, 4 expansion or' bringing . state-of-the-art _ equipment on site- into routine operation.. .i

RESPONSE

~ Over the. past several years, chemistry program . improvements ' have -

been . implemented -in a . deliberate- and ~ integrated manner with.

g emphasis?on efficiency _and cost-effectiveness. Available manpower has been-allocated to-ensureithat the' plant chemistry surveillance

i program is notL compromised in: favor of placing new complex: analyti-~ .

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cal instrumentation'into' service.

.The-(Authority has been aggressive in' identifying areas where improvement or upgrading i_s warranted ~. This has been done through. -

twoJ primary mechanisms : a comprehensive appraisal of the plant, chemistry program by the' Nuclear Steam Supply System (NSSS)-vendor 1 .

,and a task -- force composed of' Authority- . personnel; Over the past '!

four years this. task force has been working steadily to ' resolve L the. numerous recommendations from this appraisal including . the acquisition ~of'new state-of-the-art analytical equipment.

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Since this' appraisal, a'second Chemistry / Radiochemistry. Supervisor:

and a Chemical' ~ Engineer have~ been added ,to the . plant. staff .to -

facili. tate- implementation of previously identified ' upgrades. ' At -

this. time, procedures.for the_. chemistry laboratory. instrumentation: ,

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-reviewed during the' appraisal have been formalized and 'this equip. y ment'is now in routine use.- a 1

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FINDING: 4.0.b  !

Criteria for radiochemistry-QC checks are'not clear.

. RESPONSE: j The contractor quality control -(QC) sample disagreement noted in section 4.3'of the appraisal report was not investigated: however,

'a second. set of QC samples was promptly sent to the contractor laboratory. The second set of results were in agreement and met a'cceptance criteria. Subsequently, the chemistry QA/QC program was revised to include a " Sample Nonconformity Report" to be completed'

'for future ' disagreements. This form provides a mechanism . for investigating-QC disagreements and documenting the results.of such investigations. Appropriate chemistry personnel are aware of this form as well as the acceptance-criteria for QC samples. -

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-FINDING: 5.0.a i

Exposure goals are not challenging or aggressive. )

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RESPONSE

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The Authority does not totally agree with this finding. 'We believe l

.that our. goals over- the past several years have been reasonable considering plant age, planned work activities and economic-considerations. The Authority acknowledges that the 1986 exposure goal was easily achievable and actual exposure . was far below-projection; however, as previously' explained this occurred due to the delay l of several major. work . items. The Authority recognized well before years' end that the goal would easily be achieved, however, the Authority's policy is to not adjust established goals in either direction.

The Authority does recognize the need for further, more dramatic reductions, and.as a result, a chemical decontamination is planned i in the 1988 refueling outage. This decontamination effort, as stated in the appraisal report, is expected to produce a dose savings of approximately 300 man-rem. In addition, hydrogen water j chemistry (HWC) is being implemented as another major dose-saving j initiative to- avoid replacement of the reactor recirculation j

. system' piping. The evaluation of other processes and technologies i to reduce in-plant radiation buildup is' ongoing.

Aggressive goals have produced.a significant reduction in the size of contamina'ted- areas. ' During 1987 the size of these areas has ,

been reduced by 30 percent and an . aggressive goal of allowing i access to the crescent areas, refuel floor and several other areas of the plant without the use of protective clothing has been established.

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, a e r y FINDING: 5.0.b Need active participation in ALARA program by work groups and design engineers.

RESPONSE

l The' corporate Radiological Health and Chemistry (RH&C) Group has l

conducted ALARA - awareness training.- This. training, started in 1985, has included approximately 100 personnel from diverse groups ,

within- the Authority's Corporate Office. Additional training i c_ourses 'for engineering personnel - are under development and L are scheduled to .be presented in the fourth quarter of 1987 to approximately 170 persons.in the' corporate staff.

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An ALARA Engineering -Course, taught by General Electric, i presented'to 9' Authority engineers in 1986. This course is to1be i repeated in the fourth quarter of 1987.and is projected to include approximately 12 engineers. The corporate . RH&C group has also established an ALARA resource center in the White Plains Office i that includes a ' laser. disk-based video mapping- system with  !

walk-around capability to assist. planners and designers in evaluating potential interferences in high radiation areas of the plant. ,

The site ALARA Committee has been and' continues to be effective in maintaining ALARA awareness at the plant level. Pre-j ob - briefings and work reviews,. mock-up training and the plant suggestion  !

program < have been e'ffective in bringing forth ideas for dose .'

reduction. : Efforts'are on-going to involve individual departments to establish their goals both individual and collectively.

Efforts to improve th'e involvement of engineering and site  !

1 personnel in the ALARA process are always an on-going process.- _

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. FINDING: '6.0.a'

. The whole body counting facility- is improperly located for~ use -under ' accid?nt conditions.

RESPONSE

During accident conditions the Authority will use other facilities

.whole body counters in accordance with emergency planning agreements and/or contract mobile counters.  :

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The calibration ' facility is too. small and crowded, i

RESPONSE: e I A new 'admiriistration f acility is scheduled to be completed as part

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of.'the NYPA capital improvements y prograin. The ~ facility will.

provide for an -imporved calibration area, other alternatives are under consideration as' interim or substitute long-term solutions.

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~ FINDING': 6 . 0.' c An excessive number.(50 to'80%) of survey instruments are out~of> service.

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RESPONSE:.  !

An adequate- ' number .of. operable, calibrated. instruments are i available to - support the radiological protection program. The Authority has recognized a problem in obtaining spare parts _for:

certain models of portable survey ' instruments ~ and has. compensated' for this by maintaining a large inventory to ensure 'an adequate i

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FINDING: 6.0.d Portal monitors are neither L calibrated nor source checked. Friskers will not detect hot particles'at observed frisking speeds.

RESPONSE

.. . . l The portal monitors referencednin the appraisal have' been retired l from ' service and have been replaced with high-sensitivity whole body friskers at egress points from the restricted area. These i monitors . replace manual whole _ body frisking techniques and have i adequate sensitivity to _ detect hot particles. The operation and c calibration of these high-sensitivity whole body friskers is .l controlled by an approved RES Department procedure.

The original portal monitors are being retained at the Main Security and Secondary Access facilities to detect incoming radioactive material an'd to provide an additional monitoring capability for ! personnel exiting the protected area. A procedure for testing of these monitors will be developed-by December 31, 1987.

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. FINDING: . ' 6 . 0 '. e . i

' Respiratory group.is; understaffed to support the scope.of work. i

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.i This is; addressed in the. response.lto 1.0.e l

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FINDING: 6.0.f There . is a lack of coordination -of - RP responsibilities - for equipment- purchased i by other groups.

. RESPONSE:

The equipment cited in the inspection report represents 'an ,

isolated incident. The control of equipment that.is intended for~

use in the restricted areas of the plant is provided through the radiation . work permit and' ALARA review processes - in - addition" to vigilance. maintained by radiation protection personnel located ' at-the principal- access point to the re s tr:' cted - area 'and .in performing plant radiological surveillance.

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• FINDING: '6.0.g The review of routine surveys does not detect technical errors.

FINDING: 6.0.h High alpha activity detected during routine surveys is not investigated. High volume air samples are not periodically checked for alpha activity.

! RESPONSE:

These two items are the result of a single observation.

The surveys that form the basis for this finding are routine

. low-volume air samples. Review activities-are prioritized to place the greatest emphasis on the most critical areas such as the oversight of Radiation Work Permits (RWPs) and routine radiation and ' . contamination surveys. The high alpha result cited in the Appraisal Report was due to a technical error in the low-volume air j sampling procedure. This resulted in naturally-occurring radon daughter activity being counted as unidentified alpha. The error i has been corrected and additional guidance. on reporting of

. anomalous results to radiological supervision has been incorporated '

into the procedure. In addition, the need for timely review of routine survey results has been emphasized to radiological  ;

supervision.

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I FINDING: 6.0.1 Responsibilities for various fa..ets of the surveillance program is fragmented.

RESPONSES  !

The- plant radiological. surveillance program is functionally l idelegated to those groups. responsible for the appropriate l monitoring activity (i.e. air monitoring is performed by the j respiratory protection group, radiation and contamination surveys are performed by the radiation protection group and long-term trending of dose rates is performed by the radiological engineer-ing group.) The Authority does not consider the functional assignment of these duties to be a programmatic weakness since routine results are under the cognizance of the Health Physics .'

General Supervisor. Long-term dose rate trend analysis is closely associated with the ALARA program under the cognizance of the Radiological Engineering General Supervisor.

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