ML20005F197
| ML20005F197 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/26/1989 |
| From: | Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005F191 | List: |
| References | |
| 50-333-89-21, NUDOCS 9001160041 | |
| Download: ML20005F197 (9) | |
See also: IR 05000333/1989021
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No.
50-333/89-21
Docket No.
50-333
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License No.
Category C
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Licensee:
Power Authority of the State of New York
P.O. Box 41
Lycoming, New York 13093
Facility Namc: James A. FitzPatrick Nuclear Power Plant
inspection At:
Lycoming, New York
Inspection Conducted:
November 27 - December 1, 1989
Inspector:
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P. O'Connell, Radiation Specialist
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Approved by: /
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Chief ( Fac~1Tities Radiation
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- W. Plsciak, Sectio)n
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Protection
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Inspection Summary: Inspection conducted November 27 - December 1, 1989
( Inspection Report No. 50-333/89-21 )
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Areas Inspected: This inspection was a routine unannounced radiological
controis inspection. Areas reviewed include: Licensee Actions on Previously
Identified Items, Audits and Appraisals, External Exposure Controls, Control
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of Radioactive Material, and ALARA.
Results: Within the scope of this review one open item was reviewed and closed
and two apparent violations and one unresolved item were identified. The first
apparent violation involved a failure to perform an adequate survey and the
other apparent violation involved an example of a failure to comply with
radiation protection procedures.
9001160041 891229
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Details
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1.0 Individuals Contacted
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New York Power Authority
- R. Liseno Superintendent of Power
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R.Locy,bperationsSuperintendent
- J. McCarty, DosimetRadiation Protection Supervisor
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- M. McMahen,
Supervisor
- E. Mulcahey, Radiol
ical and Environmental Services Superintendent
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J. Solini Health P sics General Supervisor
- K. Szeluga,, Radiolo cal and Environmental Services Supervisor
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Quality ssurance Supervisor
- G. Tasick, Radiological Engineering General Supervisor
G. Vargo,
1.2 NP.C
R. Plasse
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- W.Schmidf,NRCResidentInspector
NRC Senior Resident Inspector
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- Denotes those individuals attending the axit meeting on December 1,1989.
The inspector also contacted other licensee and contractor personnel.
2.0 P_urpose and Scope of Inspection
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This inspection was a routine unannounced inspection of the licensee's
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radiological controls program. Aren reviewed included Licensee Actions
on Previously Identified Items, Audits and Appraisals, External Exposure
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Controls, Control of Radioactive Material, and ALARA.
3.0 Licensee Actions on Previously Identified Items
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Closed (50-333 89-13-01) Violation. The inspector reviewed the cerrective
actions taken
the licensee in response to an incident which occurred
on June 12 198 where several workers received unplanned exposures
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resulting rom a hig ly radioactive narticle rising to the surface of the
S)ent Fuel Pool (SFP , The root caus'e of the incident was a failure of
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tie licensee to cond et an adequate evaluation of the radiation hazards
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associated with introducing potentially buoyant materials into the SFP.
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1989 the licensee submitted their response, JAFP 89-0649,
On September 5,f Violation outlining their corrective actions. The
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to the Notice o
corrective actions included:
-Surveying the SFP and associated areas to locate any other
potentially bueyant objects.
-Revising several proceduras to reflect upgraded radiological
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controls including requiring the wearing of alarming dosimeters
when wor, King near the SFP removing buoyant material frc'n the SFP,
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andenhancing"hotparticle"controlsforSFPworkactivities.
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-Providity enhanced supervisory oversight of radiologically
sensitive work activities.
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-Providing training on the incident to workerc involved with SfP
work activities,
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The insoector verified th. 411 of the corrective actions specified in
the licensee's response were satisfactorily completed. This item is
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closed.
4.0 Audits and Appraisals
ector reviewed the licensee's implementation of Procedure RPOP-7
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The ins $gical Incident Investigation and Reporting"i(RIR). T
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is used to document such incidents as poor radiolog cal work practices,
personn91 contaminations, and failure to follow radiation protection
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procedures. Several of the closed RIRs did not document any corrective
actions or other final resolution. The inspector discussed this matter
with the Radiological and Environmental Services (RES) Superintendent.
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The RES Superintender.t was aware as to what corrective actions had been
taken for the RIRs in question, however these corrective actions had not
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been documented. The RES Superintendent stated that the licensee would
ical Review Form which is attached to
evaluate how to change the Radiolokions and the final resolution prior to
the RIR, to document corrective .ac
closing the RIR. This item will be reviewed during a future inspection.
The licensee also implements a Manager Observer Program in which
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supervisors in the RES De)artment tour the facility, observe work
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activities and document t1eir findings. The inspector reviewed these
documents and noted that the RES Superintendent and other RES Supervisors
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had been satisfactorily implementing this program.
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The inspector spoke with the RES Superintendent as to whether independent
corporate addits of the radiation protection program had been conducted.
The RES Superintendent stated that approximately two yet.rs ago the
corporate staff underwent reorganization and corporate audits of the
radiation protection program had bee'n discontinued.
The inspect 0r noted that the Radiation Protection Manual, Chapter 17,he
$ 1988,
requires, in cart, in Section 17.4.1
that t
dated February io,gical Health and Chemlstrylb[ Nuclear Cen
Manager - Radio
Department White Plains Office is respons
ie for corporate monitoring
andsurveillanceoftheradiatio)nprotectionprogram.
The inspector reviewed the audits of the radiation protection program
which the Quality Assurance Department conducted. At the time of the
inspection, Quality Assurance was conducting an audit of radiation
protection records. The two most recent Quality Assurance audit of the
radiation protection prooram which RES management and Quality Assurance
management provided the inspe,ctor, were conducted in February 1986 and in
Octouer 1988. The earlier audit was an audit of Respiratory Protection
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Training and the later one involved review of enforcement follow-up
actions.
The Quality Assurance Supervisor stated that Quality Assurance audits are
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routinely conducted for areas specified in the Technical Specificatione
Assurance audits of the radiation (REMP), tr)aining etc., b
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i.e. Offsite Dose Calculation Manual (0DCM , Radiological and
Environmental Monitoring Program
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protection program were not included in
the 1989 Quality Assurance audit schedule and are not routinely
scheduled. The licensee stated that two years ago the Quality Assurance
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Department had two Radiation Protection Specialists who routinely
conducted Quality Assurance audits of the radiation protection program
but these positions had been deleted.
The ins ector noted that the Radiation Protection Manual, Chapter 17,
1988, requires, in part, in Section 17.3.1, that
dated F bruary 3, d surveillances are to te performed by the Quality
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periodic audits an
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Assurance staff in accordance with the Quality Assurance Program. The
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Quality Assurance Program dated June 15, 1987, requires
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Section 17.2.18.3, thatplannedandperiodicauditsarelo'becarriedout
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by the Quality Assurance organization to verify all aspects of the
organization. Surveillance audits are conducted routinely on an
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unscheduled basis of ongoing or day-to-day activities to verify
satisfactory con.pletion of the activity. Specific program areas are
audited so that the total program is reaudited within a scheduled period
of ti:ne.
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It was not resolved during the ins ection whether, des ite the apparent
discontinuingofthecorporateaud$tprogramintheradiationprotection
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area corporate audits had been done in accordance with program
requirements.
It was also not resolud during the in.pection whether,
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despite the apparent lack of scheduling of Quality Assuraace audits in
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the radiation protection area, Quality Assurance audits had been done in
accordance with program requireinents.
The apparent discontinuation of
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corporateauditsoftheradiation protection program and the failure of
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Quavity Assurance to schedule and conduct periodic .surveillances of the
radiatio' protection
)rogram to ensure that the total program is
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reaudited within a scleduled period of time are unresolved.
(50-333/89-21-01)
5.0 External Exposute Controls
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5.1 Dosimetry
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The inspector reviewed several Daily Exposure Reports and verified that
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the proper authorizations had been obtained prior to allowing individuals
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to exceed the administrative dose limit of I rem / calendar uuarter. The
exposure records of selected individuals also were reviewed to verify
that the licensee had a completed NRC Form-4 for each individual prior to
allowing that individual to exceed 1.25 rem / calendar cuarter. The
inspector noted that errors made by contractors in computing their whole
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body exposures on their NRC Form-4 had been noted and corrected by the
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Dosimetry Supervisor. This indicated good supervisory oversight in t W
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area. During tours of the facility the inspector noted dosimetry Y 9
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worn properly.
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The licensee's dosimetry group processes all thermoluminescent dos 4 meters.
JTLDs) worn onsite with the exception of the TLDs occasionally worn when
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lt is necessary to monitor individuals for neutron exposure. These TLDs
are processed offsite by a contractor. The inspector verif(ed that the
contracte was currently accredited under the National Voluntary
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- Laboratory Accreditation Program (NVLAP) in Categories I through VIII,
inclusive.
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The inspector reviewed the licensee's NVLAP accreditation for the TLDs
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processed onsite. The licensee's NVLAP accreditation is effective until
October 1- 1990 for Categories II
IV, VI, and VII. The licensee's
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accreditafion encompasses the following types of radiation:
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Accidents, high energy photons, (Category II)
High energy photons, (Category IV
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Photon mixtures low energy and hhgh energy photons
Mixturesofphof.onsandbetaparticles(CacegoryVII)(CategoryVI)
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- The licensee stated that individuals 8 their facility are not exposed to
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other types of radiations such as pure low energy photons (Categories I
believe)It was necessary to be acc(Category V)those categories., therefore they d
and III
or pure beta particles
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redited in
The inspector reviewed the quality control checks which the licensee
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performs on the TLD processor. The quality control checks consist of
control TLDs being processed with each batch of TLDs being processed,
biweekly testing of the processor and blind sample TLDs being sent to the
licensee six times a year by a contractor. The licensee's quality
controls appeared to be adequate.
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The iaspector noted that the licensee's dosimetry algorithm recorded
- whole body doses based on TLD readings through 1000 mg/cm^2 of tissue
equivalent absorber and the licensee did not have procedures in place to
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ensure that individuals' eyes are shielded with a material having a
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density thickness of at least 700 mg/cm^2. NRC Form-5 states "Unless the
. lenses of the eyes are protected with eye shields, dose recorded as whole
body dose should include the dose delivered through a tissue equivalent
absorber having a thickness of 300 mg/cm^2 or less".
-The licensee stated that they record whole body dose through 1000 mg/cm^2
of absorber'because NVLAP accreditation requires that amount of absorber.
The licensee stated that they did not feel it was prudent to generate a
second algorithm, that was not NVLAP accredited, to assign whole body
dose. The licensee stated that several years ago they conducted a study
which determined that, at their facility, the same dose was delivered
through 1000 mg/cm^2 as was delivered through 300 mg/cm^2, however the
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licensee could not locate this study during the inspection. The licensee
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supplied the inspector the results of another evaluation, completed
during the inspection which compared the TLD element 3 (300 mg/cm^2
absorarfreadingwitktheTLDelement4 1000 mg/cm^2 absorber)-for 135
TLDs. Th9s comparison indicated no measura(ble differences between the
readings.of the two elements.
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The licensee's evaluation stated that electronic equilibrium may not be
achieved at 300 mg/ca^2 for 6 Mev photons. This would make the 300
mg/ca^2 measurement nonconservative. The evaluation also stated that
reactor coolant samples showed that the mean beta energy found at their
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facility was 0.313 Mev which is less than the minimum beta energy
required to penetrate 300 mg/cm^2 (approximatel
0.8 Mev . Based on this
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determination and the above TLD comparison stud , the lic)ensee concluded
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that recording whole body dose through 1000 mg/ m^2 was adequate at their
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facility.
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The. inspector reviewed several dose generation reports and noted that
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there did not appear to be measurable differences between TLD element 3
absorbe/cm^2 absorber) readings and the TLD element 4 (1000 mg/cm^2
(300 mg
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r readings. The inspector stated that within the scope of this
ins)ectio)n, the licensee's method for assigning whole body dose appeared
to >e adequate. The inspector stated that a change in the-isotopic
concentrations of radionuclides found at their facility that results in
higher energy betas isuch as fission products in the reactor coolant)
being found in-the plant would require the licensee to' reevaluate or
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change _ their method of assigning whole body dose. This item will continue
to be reviewed during future inspections.
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5.2 Posting and Control of Areas
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The ' inspector reviewed the licensee's program for issuing and controlling
the keys used to lock High Radiation Areas (HRA) in the plant..All HRA
keys were accounted for either in the HRA Key Control Issue 1.og or
permanently: issued to an individual. During tours of the facility the
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inspector verified that HRA doors were locked.
-Thr. inspector conducted several tours of the facility verifying that
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areas were properly posted and personnel access controlled for radiation
protection purposes. While touring the reactor building on November 28,ll
1989, the inspectormoted that the general area dose ratcs on the drywe
ozzanir.e were above 100 millirem /hr. Access to this area was not
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controlled in accordance with Technical Specification 6.11 (a)h 10 CFR
area was not posted as a High Radiation Area in accordance wit
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20.203(c). The most recent survey of this area was dated November 3,1989
and indicated the general area dose rate to be 50 millirem /hr. The
licorsee surveyed this area, after the inspector brought this matter to
Radiation Protection (RP) Supervision's attention, and determined the
general area dose rate to be 280 millirem /hr.
The inspector stated that this was an apparent violation of
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.10 CFR 20,201 (b)de such surveys,as (part, that each licensee shall make
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to' comply with the regulations in this)part, and (2) are reasonable under
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the circumstances to evaluate the extent of radiation hazards that may be
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present. (50-333/89-21-02)
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1he licensee's innediate corrective actions for this finding included-
properly posting the area and surveying other areas of the facility to
ansure that this was an isolated occurrence. The licensee also stated.
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that, in the future the survey frequency of this area will'be increased ~
frommonthlytoweekly.
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5.3 Control of Survey Instruments
The inspector reviewed the calibration- and source checking of radiation-
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survey nieters including the licensee's integrating alarming dosimeters.
OnNovember2)bhadnotbeensourcecheckedsinceNovember
1989 an individual was issued-an integrating alarming
dosimeter whic
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Procedure PDP-12 " DOS-502A Alarming Dosimeters" states that these-
dosimeters should be source checkec prior to use to ensure that they are
functioning properly. The inspector reviewed the Eguipment Issue Log and
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noted no other examples of survey instruments or alarming dosimeters-
being-impro>erly issued. The inspector verified that survey instruments
in use had >een source checked prior to use and had current calibrations.
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Control of Radioactive Material
While reviewing the background count data and check source count data-for
the background point the ins ector noted that from
the counting equipment at the control
on the SAC-4 No. 440) ranged from
November 8 to 28, 1989
15 to 42 counts per 10 minutes. The instrument had ot been.
decontaminated and RES Supervision had not been notified of the high
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background count rate.
The inspector noted that Procedure RTP-23 " SAC-4 Scintillation Alpha
Counter Operation and Calibration"' dated November 23, 1987, requires, in
per}0 minutes,thendecontaminate-theinstrument"greaterthan3 counts
part in Section 4.6.1 that "if the background is
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. Section 4.8 of this
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procedure also requires notification of a Radiological and Environmental
Services (hrou)gh the use of this procedure. Supervisor if any problems are en
resolved t
This is an example of an ap)arent violation of Technical Specification 6.11 " Radiation Protection )rogram" which requires in part, that
procedures for personnel radiation protection shall be prepared and
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adhered to for all plant operations. (50-333/89-21-03)
The inspector roted that the high background count rate on this counter
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resulted in th counter having an unacceptably high lower limit of
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detection (LLD). The counter's LLD was higher than the licensee's limit
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for removable contamination on objects being released from the radiation
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. controlled area and the limit used for posting contaminated areas. The
' daily background counts and source check results of the counting
. equipment had not routinely been reviewed by RP-Supervision which
indicated that RP Supervision oversight of this area needs improvement.
7.0 As Low As Reasonably Achievable (ALARA) Program
The: inspector observed the training of the individuals involved in'the.
transfer of resin from the phase separator to a high integrity container
(HIC for shipment offsite to a disposal site. The licensee estimated
that)the exposure rate at the top of the HIC,ALARA planning-for th
where individuals needed to
secure the lid,-could approach 100 R/hr.-The
activity was good. Prior to transferring the resinextensive use of temporary shieldin
ten monitors, remote
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handling tools,= and several, timed,-mock-up practice runs in order to
minimize-personnel exposure during this evolution. During the~ALARA
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pre-job briefing, good. communication was noted among all the individuals
involved in the transfer including radiation protection personnel
contractor workers, and plant operators. Although the. entire job ,-
the inspector did note
evolution was not completed during the inspection
that the radiation protection coverage of the initial phase of the
transfer was good.
The inspector reviewed a plant-modification work package which indicated
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that the engineering-design stage for plant modifications did not-
effectively take ALARA into consideration. Proper planning was not -
conducted for the installation of the jet p mp instrument drain line
which was completed during the outage in Se tember. The instrument drain
line had-been improperly installed such tha the recirculation pump seal
carrier could not be moved. As a result of this error, the instrument
drain line had'to be removed, shortly after it was installed, so that the
recirculation pump seal could be replaced. The instrumant drain line then
had to be reinstalled. During the next outage the instrument drain line
will have to be removed again and rerouted correctly.
The removal and reinstallation of the instrument drain line resulted in
an additional four man-rem of personnel exposure. Additional emphasis
duririg the engineering design
needs to be placed on thorough planning,high exposure work activities.
stage of plant modifications, involving
The 1989 ALARA goal was 300 man-rem. At the end of November 1989 the
licensee had already exceeded their ALARA goal by 44 man-rem. ALARA
due to unanticipated work activities during the three week mini primarily
personnel stated that the reason the goal had been exceeded was outage in
September. The ALARA department projected 116 man-rem for the outage and
the actual cumulative outage exposure was 167 man-rem.
The inspector reviewed and discussed with ALARA personnel several of the
ALARA post job reviews of major outage work activities. The inspector
reviewed ALARA post job reviews of several unanticipated work activities
which were completed during the outage. These work activities accounted
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for the majority of the personnel exposure.in excess of the ALARA outage-
pro 1ection. Notwithstanding the area for improvement noted in the
engineering design stage of plant modifications, the ALARA group was
effectively' implementing the licensee's ALARA program.
8.0 Exit Meeting
The' inspector met with licensee representatives (denoted in Section 1)lat
the conclusion of the inspection on December 1,1989. . The inspector
summarized the purpose,-scope, and-findings of the inspection.
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