ML20044A931

Responds to NRC 900611 Ltr Re Violations Noted in Insp Rept 50-333/90-17.Corrective Action:Suspended Surveillances Reinstated on 900507

ML20044A931
Person / Time
Site:	FitzPatrick
Issue date:	07/06/1990
From:	Fernandez W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JAFP-90-0517, JAFP-90-517, NUDOCS 9007170007
Download: ML20044A931 (5)

Text

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James A. PNspeMek

. Musiest Peeer Mont i i

P.O. Box 41

,', Lycoming. New Y:rk 13093

. 316 342 3640  ;

William Femandez 11 Resident Manager l July 6, 1990 JAFP-90-0517 i

U.S. Nuclear Regulatory Commission Mail Station Pl-137 l Washington, DC 20555 l ATTENTION DOCUMENT CONTROL DESK

SUBJECT:

RESPONSE TO NOTICE OF VIOLATION -

INSPECTION NO. 90-17 (DOCKET 50-333)

Reference:

1. USNRC Letter Dated June 11, 1990

Subject:

Inspection Report 50-333/90-17 ,

Enclosure:

Response to Notice of Violation Gentlemen (

In accordance with the providions of 10 CFR 2.201, the Authority is ,

submitting our response to Anoendix A Notice of Violation i transmitted by your letter (Reference 1), dated June 11, 1990. 3 This refers to the routine unannounced radiological controls j inspection conducted by Mr. Peter O'Connell between May,5 to 11, +

1990 at the James A. FitzPatrick Nuclear Power Plant.  ;

Very tru;Ly.yours, j_ ,_.

• ILEIAM FE ANDEZ WF/GJV Y

enclosure 3

cci. R. Beedle, WPO J. Ellmers J. Brons, WPO R. R. Bellamy, NRC Region I-DRSS i R. Liseno Document Control Center ,

l G. Vargo ..

WPO Records Management NRC Sr. Resident Inspector - JAF  ;

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CERTIFIED MAIL - RETURN RECEIP'l itEOUESTED

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, ENCLOSURE 1 - "

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s ig NOTICE OF-VIOLATION' x

" As;a. result of the inspection conducted on May 7 to 11, 1990 and

. accordance with the NRC Enforcement Policy (10 CFR 2, Appendix

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C)', the following_ violations were identified.

S ' L't Technical Specification 6.11, Radiation Protection Prog ~ ram,

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states, in part, that " Procedures for personnel re.diation-m

. protection shall be prepared and adhered to'for all plant W ,

4 operations.."

Chapter 15 of the Radihtion-Protection Manua? " Radiological Surveys",, requires, in part, in Section 15.4.V, that

" Radiation and contamination checks of high~ occupancy areas

.such as officea, lunchrooms and locker rooms are 31so

_ performed weekly."

Contrary to'the:above, radiation and contamination cl.ecks of

,high occupancy areas such as offices, lunchrooms and locker 7_ + rooms had not been performed weekly from April 3, 1990 to

,q , M a y 7 ',- 1990.

,p This is a Severity Level IV Violation (Supplement 1IV)

. B. Technical Speuification 6.5.1 (E), Plant operating Review

Committos_(POPC) Responsibilities, requires PORC to review tplant' procedures, and changes thereto, required by Technical Specification 6.8 L'

. Technical? Specification;6.8, Procedures, requires, in part, that written procedures and administrative policies shall be established and maintained that meet or exceed the requirements and recommendations of Appendix A of Regulatory 1

. Guide l.33, November 1972.

Appendix A of Regulatory' Guide 1.33, November 1972, i requires,3 in part, that the following are typical safety-related activities =which'should be covered by written c~

procedures - Restrictions and Activities in Radiation Areas and High Radiation Areas, Respirator Equipment, Surveys and

. Monitoring, Protective Clothing, and Radiation Work Permit Procedure.

~ Contrary to the above, ne of May 11,'1990,- PORC had not

< reviewed = Radiation Protection Procedures, inu.uding RPP-4,

-Radiation Work Permit Procedure, RPP-5, Plant Radiological Surveillance Program, and RPP-9, Radiological Survey Techniques.

This is a severity Level IV Violation. (Supplement IV) s r .

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.C.- Technical Specification 6.21 (A), High Radiation Area (HRA),  ;

'; requires, in part, that any individual or group of i individuals permitted to enter a HRA shall be provided'or accompanied by either a continuously indicating radiation  ;

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monitoring device, an integrating alarming dosimeter, or'an ,

c 4 . individual qualified in radiation protection procedures-who 1 Ly '

is equipped with a radiation dose rate monitoring device who j performs periodic radiation surveillance at the frequency

= specified in the Radiation Work Permit (RWP) . R t 1 ,

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Jcontrary to the above, individuals, working under the- l g control of'the various RWPs including Regular RWP 90-3369 i L .

dated May 5, 1990, Regular RWP 90-3168. dated May 5, 1990,

, ,# 3 Regular RWP 90-3217 dated May 7, 1990 and Continuing RWP 90-

0387, entered into HRAs without joing provided or i accompanied by one of the three options specified in i s' Technicalispecification 6.11 (A). In addition, the above l referenced RWPs did not specify frequencies for. periodic j surveillance of the area. l o l L This is a Severity Level IV Violatior;. (Supplement IV) I i'

a RESPONSE l l A. The Authority agrees with the violation. I

.This, violation resulted from the proper = temporary suspension j of portions of the radiological surveillance program l Ldelineated in procedure RPP-5, " Plant Radiological .)

Surveillance Program" without performing the necessary 1 concurrent temporary change to the Radiation Protection i L '

Manual which requires review by PORC. .The temporary 1

' suspension to.the procedure was made with the concurrence of

'both the department superintendent and. Resident Manager.

The suspension'was made as a result of a shortage of.  ;

qualified radiation protection personnel during the early I l

o 'part of the refueling outage, -

r The corrective action for this' violation was a' reinstatement of'the suspended surveillances on May 7, 1990. Full compliance wasfachieved at that time.

The interface between the' Radiation Protection Manual (RPM) and implementing procedures is somewhat i

. confusing;'thatiis, many details overlap which can l result inisimilar violations. To correct this -1 I

situation, a review of the RPM and' implementing

procedures will be performed to reduce the overlap and thus clarify PORC review requirements by July 1991.

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M  ; - ' t-u 14 BE. The Authority does not agree with this violation.

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The' Radiation Protection Manual, the governing document that establishes radiation protection policies and requirements, is reviewed by PORC. . Implementing procedures.that address ,

the Radiation Protection Manual's requirements are prepared i and issued without PORC review. Separate procedures govern l the review and approval of these implementing. procedures.

The concept of a Radiation Protection Manual was )

identified by the Authority in 1983 as a' programmatic upgrade. Work on this document progressed through 1985 and the existing Radiation Protection Manual was implemented on January 1, 1986. The former'" Radiation l

' Protection Procedure", the single procedure that contained.all radiological protection requirements, was withdrawn at.that time in favor of separate detailed implementing procedures. This upgrade received numerous reviews during its preparation and following its implementation.

.During an appraisal of the radiological program at FitzPatrick (Inspection Report 50-333/87-18), the Radiation Protection Manual was cited as a programmatic strength.

The Authority believes that PORC review of the i Radiation: Protection Manual meets the requirements of i Technical Specification 6.5.1 and 6.8. J l

The practice of requiring PORC review for program or administrative _ documents and not requiring a similar review j

'of detailed implementing procedures at FitzPatrick has been 4 reviewed previously by the NRC and'found to-be acceptable.

Examples of this include engineering, welding.and non- ~~

' destructive examination procedures.  ;

C.- The Authority agrees with.the violation,,in that no

frequency was specified on'the' identified RWPs; however, RES technicians'were~ assigned to, provide radiological oversight Rof the individual sork tasks.

This violation was caused by a weakness in the Radiation  ;

- Work Permit (RWP) Procedure which'did not explicitly require Lthat a monitoring frequency be stated on all RWPs. RWPs at 1 4 'FitzPatrick are generated from area surveys performed I r shortly before work commencement and require a pre-job l meeting between Radiation Protection personnel and the

'leadman - for the job. of the cited RWP examples, RWP-90-3169

-was for 1 3/4 hours of work in the Torus Room; and a RES technician-provided a. follow-up inspection about half way through the job. RWP-90-3168 was for 30 minutes of work in the clean-up hold Pump Room. RWP-90-3217 was for work on the Drywell entrance mezzanine for about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the l

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l morning and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in the afternoon. A RES technician  ;

H ,s o . provided coverage all morning and about 1/2 hour in the d* '

afternoon. Continuing RWP.90-0387 was for the removal of i

. several large motors from the crescent area over a period of 1' many days. A RES technician provided radiological coverage for the job and radiological surveys were performed daily to verify conditions.

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. The short-term corrective action was a re-instatement .

of the high radiation area (HRA)' monitoring requirement l

t-and a temporary revision to the RWP Procedure to i L' require thatLall HRA RWPs contain a specified ;l p monitoring frequency or require the use of alarming i dosimetry or a dose rate: monitoring instrument. Full ,

compliance was achieved on May 7, 1990 when this I temporary revision was made. ,

The long' term corrective action'for this event (high; I

radiation area monitoring specified on RWPs) will be. .

1 I incorporated into the Authority's planned upgrade of the FitzPatrick RWP program that is scheduled for completion by December 31,.1990.

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