JPN-87-027, Submits SALP Response on Three Specific Areas of Rept Where Presentation of Addl Info Needed to Provide More Accurate Assessment.Info Re Areas of ALARA Goal Setting,Instrument Calibr Program & Nuclear Licensing Encl
| ML20214H023 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/15/1987 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| JPN-87-027, JPN-87-27, NUDOCS 8705270248 | |
| Download: ML20214H023 (6) | |
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123 Mcin Street Vdute Plans, New York 10501 914 681.6200
- > NewYorkPower 4# Authority May 15, 1987 JPN-87-027 U.
S. Nuclear Regulatory Commission Attn:
Document Control' Desk Washington, D.C.
20555
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Systematic Assessment of Licensee Performance (SALP)
Reference:
SALP Board Report No. 50-333/85-98, transmitted by NRC letter T.
E. Murley to J.
C. Brons, dated March 13, 1987.
Dear Sir:
On March 13, 1987, the Nuclear Regulatory Commission (NRC) issued the Systematic Assessment of Licensee Performance (SALP) report for the James A.
FitzPatrick Nuclear Power Plant.
A meeting to discuss the contents of this report was held in the NRC Region 1 offices on April 15, 1987.
This letter provides comments on three specific areas of the report where the presentation of additional information is needed to provide a more accurate assessment. contains additional information concerning the areas of ALARA goal setting, the instrument calibration program and nuclear licensing.
The Authority appreciates the opportunity afforded by the SALP process for improved understanding of issues related to the FitzPatrick plant.
The report has been carefully reviewed and the observations will be used as a basis for improvements in operation and support of the FitzPatrick plant.
Should you have any questions regarding this SALP response, please contact me or Mr.
J.
A.
Gray, Jr.
of my staff.
Very truly yours, 8705270248 s70515 gDR ADOCK 05000333 PDR ohn C.
Brons Executive Vice President Nuclear Generation cc:
Office of the Resident Inspector U.
S.
Nuclear Regulatory Commission P.
O.
Box 136 Lycoming, New York 13093
,//
i a
U.
S. Nuclear Regulatory Concission Region I 631 Park Avenue King of Prussia, PA 19406 Mr. H. Abelson, Project Manager Project Directorate I-1 Division of Reactor Projects-I/II U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014-I I
l
s ATTACHMENT 1 A.
ALARA Goal Setting:
NRC SALP Statement (pace 11):
"The licensee's ALARA person-rem goal for the site was 600 person-rem for 1986, a non-refueling year, based on a calculated exposure estimate of 575 person-rem.
With the accumulated exposure at the end of the assessment period, the exposure for 1986 was not expected to exceed 400 person-rem.
While this exposure reflects well on the ALARA program, it shows the goal set for the 1986 calendar year was not aggressive."
NRC Inspection 86-17 Statement (pace 5):
"For 1985, a refueling year, the licensee had established an exposure goal of 1,000 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:
1.
The licensee estimated that they would only need 575 man-rem for the year.
2.
Exposure status as of September 14, 1986, was 248 man-rem, with the potential for not exceeding 400 man-rem for the year.
3.
" 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 q
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 l
would be made to improve the setting of future ALARA goals."
Authority Response:
l The process of defining the final 1986 plant goal for man-rem exposure included several steps and inputs which unfortunately were not made clear to the inspectors during Inspection 86-17.
The determination of the 1986 goal was l
l
q.
- w made through'the following process
- 1. - 'The projected cumulative exposure for 1986 was 571.8 man-rem based on_ identified major work activities for 1986. -This included two 14 day planned maintenance outages.and 14 days of unplanned outage time.with-exposure rates of approximately 5-1/2_ man-rem:per-outage day.
This_ estimate did not include projected exposure for several jobs that were to be' scheduled-for 1986.
2.
The prior three years of FitzPatrick operations included the following exposure data:
Year Total Man-Rem Outage Rem Outage Days Rem / Day Proi.
Actual Proi.
Actual Outage Oper
'83 993 1,090 632 748 92 8.13 1.25
'84 773 971 176 645 62 10.40 1.38
'85 1,197 1,051 887 764 106 7.21 1.11 Therefore, the average outage day exposure for planned and unplanned work was about 8.5 rem and while operating about 1.25 rem / day.
Thus, based on.the 1986 proposed schedule, the projected exposure rate based on historical data was 42 x 8.5 + 323 x 1.25 = 760.75-rem.
3.
From~INPO data, between 1982 and 1984, the median yearly BWR exposure was 1,030 man-rem per unit.
In addition, 4 -
from other data (NRC). FitzPatrick's exposure history was:
Year Average BWR Exposure-FitzPatrick l
'79 733 85S
'80 1,136 2,040
'81 980 1,425
'82 940 1,190
'83 1,056 1,090 l
L
'84 1,003 971 After assessment of these three data sets, the goal was set at 600 man-rem.
This goal was chosen to provide a continued downward L
trend, challenge the work force and at the same time become a useful management parameter.
2
[
,-?s During~the course of 1986, many of the tasks planned for accomplishment had to be delayed because of manpower constraints caused by creation of the onsite construction group.
As a result, the exposure for the year was significantly less than projected, with a.
final value of 410 man-rem.
The SALP report in this instance is based on the information contained in NRC Inspection Report 86-17 and the statement that the
" licensee agreed that the goal was 'not ambitious enough'...".
There is clearly room for improvement in the area of ALARA work. practices and goal setting.
However, the data in the inspection report did not reflect all of the inputs which established the basis for the 1986 exposure goal.
This was.due to incomplete information provided.to the inspectors (ie. input from only one department). hich the Authority w
did not correct after publication of the inspection report.
B.-
Instrument Calibration Program ERC SALP Staterent (Dace 19):
"The NRC identified that not all safety-related instruments were being periodically calibrated, nor was there an adequate surveillance test to verify that they are functioning within the required ranges.
The licenbee immediately calibrated those instruments identified and was i
further evaluating the remaining safety-related instruments for periodic calibration.
Also, the delayed implementation of calibration program improvements recommended by a 1983 QA audit reflected poorly on management's interest in
. implementation high quality program (sic)."
NRC Inspection Statement 86-08 (page 6):
"The plant Quality Assurance department has performed comprehensive audits and surveillances of the calibration program in the last two years and has identified many weaknesses in the program.
Also, an internal appraisal of plant M&TE program was conducted in late 1983 (Report
- 83-02) which recommended several improvements.
- However, the plant management has not acted on these t
recommendations.
It appears that the licensee has been somewhat slow in responding to and/or implementing their own recommended improvements and the QA findings.
The licensee acknowledged the inspector's comments, and indicated that this area would receive additional management attention."
i Authority-Response:
At the time of the inspection exit, the exact status of the QA inspection 63-02 recommendations was unknown.
The Authority did not make an official response to the NRC Inspection 86-08 finding to correct the inspector's i
j observation, since prior site policy was to formally respond 1
only to violations.
5 3
i
.s,-..
[p;_ 3; s -
IA has since reviewed the recommendations _and we-believe the Q
results,.which' follow, do. rot demonstrate a poor' interest by management in implementing a high quality program:
a)
The QA inspection 83-02 was. conducted in late 1983'and the report _was issued December 5, 1983 with six broad recommendations (not tne type of issues which are quickly resolved),
b)
Recommendation 1 was implemented on September 2, 1984 with a follow-up improvement completed in 1986.
c)
Recommendation 2 was completed on February 26
-1986.
d)
Recommendation 3 was essentially implemented on September'2, 1984.
However, a couple of items remain open.
e)
Recommendation 4 was formally addressed and implemented on September 2, 1984.
f)
Recommendation 5 is an in-going effort of updating.
-record and documentation files after formal programs were implemented, g)
Becommendation 6 included-the need for follow-up audits which were' accomplished in 1985 and 1987.
h)
In March-April 1985, a follow-up examination was conducted by the same QA individual to assess the-
^
progress in implementing the recotaendations.
In a letter dated April 30, 1985, the following' statement was made:
"I am pleased to report that the Maintenance, Instrument and Control and Quality' Assurance Departments have done an excellent job implementing their responses to these recommendations."
C.
Nuclear Licensino NRC SALP Statement (Dace 27):
"The TS pertaining to recirculation bypass valves illustrates a case where wording is not consistent with intent.
Although this TS was subsequently deleted, no effort was made to revise the wording during a 6-month period from the time this TS led to a plant shutdown.to the time the deletion was requested."
l-Authority Response:
l At the time in question, tae FitzPatrick plant was shutdown as a result of a valve packing leak and not the result of technical i '
specificatione problems.
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