ML20065K801
| ML20065K801 | |
| Person / Time | |
|---|---|
| Site: | 05000000, FitzPatrick |
| Issue date: | 11/30/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML082180535 | List:
|
| References | |
| FOIA-82-261 NUDOCS 8210080134 | |
| Download: ML20065K801 (9) | |
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y J. A. FITZPATRICK Evaluation Period 12/1/79-11/30/80 j
I.
General Corrective actions taken by the licensee during of the SALP assessment period included the reorganization of the corporate management structure j;
and steps to increase staff size. A Corporate Director and Assistant E
Director of Security as well as a Site Security / Safety Superintendent were appointed and the contract security force was replaced with a utility 3
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employee force.
Ten contract engineers were added, and approval was given Sf:
authorizing forty-six more permanent engineer positions. The licensee is O-actively recruiting to fill these positions.
Additional steps taken to address the SALP identified weaknesses include:
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the revision of the implementing procedures for the plant modifications d.i program; the development and approval of a revised Emergency Plan and
'd implementing procedures; and the installation of facilities for security x
force training.
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II.
Specific in P;g Contention
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4 "The Fitzpatrick facility displayed evidence of weaknesses in eight g
hd functional areas.
These areas were fire protection, design changes and jg modifications, radiation protection, emgrgency preparedness, radioactive waste management, transportation, security and safeguards, and management P
controls."
y-These contentions are addressed as follows:
Fire Protection (See Contention A)
Design Changes arid Modifications (See Contention B) l Radiation P,rotecti.on (See Contention C)
Emergency Preparedness (See Contention D)
Radioactive Waste Management (See Contention E) l Transportation (See contention F) l Security and Safeguards (See Contention H) l-Management Controls (See Contention I)
Contention A i
"The fire protection area was characterized by several items of nonccmpliance and a failure to meet housekeeping commitments."
1.
Basis References During one inspection, it was determined that the IE Report licensee had failed to maintain adequate controls 50-333/80-17
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over the installation of fire barrier penetration seals.
As a result, QA inspection of all penetration y
work was not completed arfdmork,was accomplished i
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without the issuance of appropriate tracking forms.
Also, the licensee's program for control of combus-L:'. ' L' tibles and the housekeeping procedures also failed to l
prevent the accumulation of combustible materials in l ?p, - 2, safety-related areas.
In addition, the NRC deter-mined that the licensee failed to satisfy technical
(/h?ft specification requirements resulting in a temporary
- i. F degradation of a fire barrier separating safety-relate t
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areas.
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2.
NRC Actions
!.MN' Enforcement action was taken addressing all of the 10/1/80 TlQ3,'.
items discussed above.
Followup inspection actions NRC letter;
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confirming licensee corrective actions have been IE Reports c;dk{.
completed.
50-333/81-06 and 81-09 5
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Licensee Corrective Action
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In addition to correcting identified weaknesses, 10/1/80 Qng the licensee instituted hourly inspections of Licensee letter;
[~$p23h srafety-related areas. These inspections will' IE Reports continue for the duration of the fire protection 50-333/81-05 and s
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modification program to verify the status of fire 81-09.
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doors and penetrations. A QA,jaspection of all ycn penetration seals has been completed.
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Contention B "There were instances where the licensee had not made program revisions to the design change and modification area in accordance with commitments to the NRC."
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1.
Basis References During an October-November, 1980 inspection, the IE Report NRC determined that the Acoustical Valve Monit-50-333/79-13; p!
oring System installation was physically com-12/11/79 NRC l
pleted but that all the required actions stated letter; in the modification package were not completed 1/4/80 Licensee before declaring the system operable and that the letter; Radwaste System was modified without the updating IE Report of controlled drawings to reflect the current "as 50-333/80-21.
built" conditions of the system.
On a previous inspection with similiar enforcement action, the NRC received licensee commitments to revise the modification program procedures.
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2.
NRC Actions l
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12/11/79 NRC Enforcement action was {akeri.for drawing control
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5 inadequacies and the failure to complete the paper letter; work associated with the Acoustical Valve Moniter-1/22/81 NRC ing System modification.
The NRC continues to letter monitor the licensee's corrective ac', ion in design
-'n changes and plant modification.
3.
Licensee Corrective Actions J 1.
Subsequent to the' assessment period, the licensee 1/7/80 Licensee
.9.Vi issued the required procedure revisions to improve letter;
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the modification program.
3/7/80 Licensee
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Contention C nd5
" Weaknesses in radiation protection,... were identified during routine 4 3.Su NRC inspection efforts and durirg the Health Physics Appraisal inspection."
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Basis References
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- cMd5 The Health Physics Appraisal in-November, 1980 IE Report 50-333 5Mh identified weaknesses in the following areas:
the 80-20 (Draft) y2$h]
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external exposure control program with respect to g y;
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the neutron monitoring methods, training of 39 technicians in neutror. monitortDg, low energy beta gg radiation tests for whole body dosimetry, and the-tre quality assurance program for extremity dosimetry'
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and neutron dosimetry.
The internal exposure control program was not formalized to identify, evaluate or take corrective action for personnel exposure to airborne radioactivity. A quantita-tive respirator fit test program and a control
. and, issuance program for respiratory protective equipment had not been established. The surveillance program needed improvement in the areas of routine radiation and contamination surveillance.
Formal guidance as to the type of. radiological surveys required for radiation work permits and adequate airborne radiofodine sampling equipment had not been provided.
2.
NRC Actions An Immediate Action Letter (IAL 80-48) was issued 11/21/80 NRC addressing the specific Health Physics Appraisal Region I Letter l
findings.
Continuing review of the Radiation (IAL 80-48) l Protection Program is scheduled as a part of the routine NRC inspection program.
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3.
Licensee Corrective Actions f-Inspection Report 50-333/80-20 has not been issued by the NRC. The licensee therefore has been unable to
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respond to the specific weaknesses identified during the Health Physics Appraisal.
However, the licensee committed to review procedures and to review the y y
~~'s Radiation training program.
Corrective action initiated as a result of the management meeting
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Appraisal inspection will be reviewed during the
- M.1 next Radiation Protection inspection.
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- Contention D
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" Weaknesses in... emergency preparedness... were identified during...
.'u the health physics appraisal inspection."
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1.
Basis References During the Health Physics Appraisal conducted IE Report 50-333/
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Q in November 1980, weaknesses werq. identified in 80-20 (Draft).
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the licensee's Emergency Pre,naredness Program.
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Specific findings noted on the Health Physics Report requiring immediate '.icensee action were
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dose pro,1ections, emergency organization, and training / retraining activities ~. -
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NRC Actions The NRC issued an Immediate Action Letter (IAL 11/21/80 NRC i
80-48) to the licensee addressing these weak-Region I letter nesses and confirming licensee corrective actions.
(IAL 80-48)
,The NRC Emergency Preparedness Appraisal inspection has been scheduled to assess the current licensie performance in this area.
3.
Licensee's Corrective Actions j
The licensee took prompt corrective actions to satisfy the commitments detailed in IAL 80-48.
Additionally, the licensee has extensively revised the Emergency Plan and implementing procedures in 1
1 order to update the program in accordance with 10 CFR 50 and NUREG-0654.
Contention E
" Weaknesses in... and Radioactive Waste management were identified during routine NRC inspection efforts and during the Health Physics
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Appraisal inspection."
5 1.
Basis References The Health Physics Appraisal also identified weak-IE Report 50-333/
nesses in the Radioactive Waste Management 80-20 (Draft).
J program in the following areas:
formal assignment
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of radioactive waste shipping responsibilities; i
repair and utilization of the offgas treatment
~h-system; establishment of a radioactive waste Y
quality..surance program; and adequacy of radic-active waste staff to fully maintain and imple-wn ment a radioactive waste shipping program.
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2.
NRC Actions k"43.Q:f;[:h!
- m IAL 80-48 also addressed the weaknesses in train-IE Report 50-333/-
ing in the radwaste area.
Selected portions of 81-10 (Draft);
.$Q the Radioactive Waste Management program were 11/21/80 NRC M. e.
reviewed during an inspection conducted in -
Region I letter sit.},
April 1981.
(IAL 80-48).
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Licensee Corrective Actions hW 0 The licensee reviewed and revised station IE Report 50-333/'
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procedures for the operation of the Solid Radwaste 81-10 (Draft)
((,; -j Qj System, for waste' packaging and handling, cask handling procedures, and documentation of radwaste shipments.
In addition, trainf rig ~' courses were con-H-
ducted for selected station personnel in the Opera-DN tions, Maintenance, and Radiation Protection De-partments and for contractor personnel, on the subjects of transfer, packaging and shipment of low-level radioactive waste.
Conte.ntion F_
"The FitzPatrick facility displayed evidence of weaknesses in eight functional areas... transportation....".
1.
Basis References Four NRC inspections of waste shipments were IE Report 50-333/
conducted at the Barnwell, S.C. Burial Site.
80-14; One item of noncompliance was identified PNO-II-80-131 relating to improperly marking Radioactive Waste shipments.
On June 19, 1980, a shipping cask was received at the Barnwell BuriaT Site without the outside markings " Radioactive-LSA" to identify the contents.
The South Carolina Department of Health and Environ-
6 mental Control suspended the licensee's burial permit and imposed a $1,000 civil penalty for violation of SC 00T rules. On July 28, 1980 a shipment of radioactive LSA waste was observed to measure 300 mrem /hr (limit 200 mrem /hr contact) at the surface on a plywood box on an open bed truck.
2.
NRC Actions
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Notices of Violation were issued for the NRC 9/3/80 NRC identified item of noncompliance. The NRC letter continues to monitor licensee performance in this area.
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3.
Licensee Corrective Actions g;;f.;..
kf t.l A plant Standing Order was revised to provide 9/18/80 Licensee for reading the instructions to the transport letter
+.n r3 driver, which require his signature, specifying J
that the vehicle is to be inspected after each
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T:'M significant stop (rest, fuel, food, etc.), to 7 11 provide for the vehicle being properly
- dW placarded, the package (s) properly labeled WM'i
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. (if visible) and the cargo area properly y@M
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sealed (when required).
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g Contention G 7-
"In these areas there were instances of weaknesses in procedures, inadequate training, and personnel errors. The NRC issued an Immediate Action Letter to confirm the licensee's commitments to resolve weaknesses identified during the health physics appraisal."
(See Contentions C,D and E)
Contention H Weaknesses in security and safeguards identified 'during NRC inspections precipitated escalated enforcement action by the NRC, including a civil penalty and Immediate Action Letter."
1.
Basis References The following inadequacies were identified IE Reports through NRC inspection:
NRC was not notified 50-333/00-06 of a change to the Physical Security Plan which and 80-15 permitted improperly screened visitors to have unescorted access to the site; contractor employees were granted access without being prop,erly screened; two security force members
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had not completed initial training; two
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Secondary Alarm Station (SAS) operators had
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i not been trained in SAS operations; a mech-anica~ lock was operable from the outside using the door knob stem; a door, which was part of E
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the perimeter barrier, was not alarmed; four unprotected manhole covers provided direct
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access to the Vital Area; the licensee failed to assign an individual responsible for the
- j last access control funct' ion at the Auxiliary Control Point for a major portion of the inspec-tion; an opening at the Auxiliary Access Control
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Point was nqt covered with bullet resistant material; five active security photo badges l}i had expired; security failed to conduct hands-on
- searches of 5% of the licensee employees not L!
regularly employed at the site; vehicle was Q) escorted into the Protected Area (PA) by an
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unarmed employee; Central Alarm Station (CAS) 1; security computer failed to alarm when unauthor-j ized key cards were used to gain entrance into vital areas; the interior of the CAS was visible I;i from outside the PA; microwave units were not
<a properly installed; a radio transceiver provided as backup communications was inoperable; the radiation detectors and.interlockers at the e
turnstiles into the PA were inoperable; locks
'7 had not been changed despite the los Lof 5 vital area keys; visitor logs were inaccurate; security logs did not include required data; e
a vital area door was propped open with a brick for over five minutes; and, security personnel failed to respord to an alarm at a vital area door until ten minutes after it was called to their attention by the inspector.
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2.
'NRC Action!
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Representatives of NRC met with members of the 8/21/80 NRC Region licensee's staff in New York on April 25, 1980, I letter; a
to discuss the results of the physical security IE Reports 50-333/
l inspection conducted April 14-18 and April 80-13 and 80-18; i
23-25.
An Immediate Action Letter was issued 10/29/80 NRC requiring prompt correction of the problems iden-letter (Civil tified.
A Civil Penalty of $48,000 was imposed.
Penalty Order)
EA-80-44 Other NRC actions included:
a followup inspection IE Report was conducted on August 18-22, 1980; a special 50-333/80-15 inspection by a Region I inspector and an NRC Headquarters observer to review the contingency
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' security force that was implemented on September 21, 1980.
Routine faspections are conducted by the resident inspector.
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3.
Licensee Corrective Actions The licensee has taken action to correct each 9/20/80 Licensee specific problem. An. independent security con-letter sultant was retained to audit, recommend, and I
assist in implementing the Nuclear Power Plant Security Program.
The' Security organization was restructured and 10/14/80 Licensee augmented by adding five management employees to letter f
act as Security Shift Coordinators. A security manager from the Corporate staff was assigned to the FitzPatrick site to audit and assist in implementing the physical security program.
On September 21, 1980, the licensee terminated the contract guard services and initiated a security force of utility employees.
Contention I "The FitzPatrick facility displayed evidence of weakness in... management controls."
1.
Basis References
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Weaknesses in the management controls area IE Reports 50-333/
were identified during the evaluation period 80-05 and 80-21 as a result of routine NRC inspections.
Examples of these weaknesses include:
failure to establish and implement calibration procedures for the Reactor Core Isolation Cooling System and the Recirculation system; failure to review surveillance procedures; failure to control pr.ocedures involved. in plant operations; and failure to review maintenance procedures within the prescribed time interval.
Further indication of a weakness in management controls is shown by the degradation of the station's physical security program that was identified during the April 1980 inspection.
2.
NRC Actions As discussed in Contention G above, a civil IE Report 50-333/
penalty was assessed in the security area.
80-06; NRC continues to monitor the licensee's corrective 8/21/80 NRC action in the management controls area.
Region I letter; 10/29/80 NRC letter, EA 80-44.
9 3.
Licensee Corrective Actions To resolve the problems associated with the 6/7/80 Licensee failure to establish and implement calibration letter; procedures and the failure to review maintenance 8/7/80 NRC letter; procedures, the licensee committed to revise the 10/28/80 Licensee station procedures applicable in these situations letter; and to conduct training to insure future compli-IE Reports 50-333/
ance with the requirements in these procedures.
81-06 and 81-09; With respect to the failure to review surveillance also see test procedures, the licensee revised the three Contention G.
applicable station procedures and conducted training I
in the applicable administrative procedures.
To correct the problem associated with the inade-quate controls of operating procedures, the licensee reviewed station operating manuals and made appropriate changes and additions.
- Also, i
the licensee began a program of quarterly manual reviews conducted by the Operations Department Superintendent to prevent use of out of date or incomplete procedures.
To further address weaknesses demonstrated in "fr&g:
t.his area, the licensee strengthened management controls by the addition of staff eng.ineers in the corporate office.
The licensee also took firmer control of the Security program'3_nd has established a security force of utility employees.
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