ML20151E500
| ML20151E500 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/07/1988 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 8807260097 | |
| Download: ML20151E500 (2) | |
See also: IR 05000333/1987018
Text
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JUL 0 71989
Docket No. 50-333
q
Power Authority.o" the State of New York
James A. FitzPatricK Nuclear Power Plant
ATTN: Mr. Radford J. Converse
Resident'. Manager
P. O. Box 41
Lycoming, New York 13093
.,
Gentlemen:
.
Subject:
Inspection 50-333/87-18
This refers to your letter dated October 26, 1987 in response to o,,r letter
dated August 19, 1987.
Based on a telephone discussion between H:. W. Thomas
of this office and Mr. G. Vargo of your staff on June 20, 1988, we understand
that you did not receive a letter from the NRC acknowledging the receipt of
your September 26, 1987 letter. A copy of your response was~ resubmitted to.
Region I on June 20, 1988.
t
Thank you for infurming us of the corrective and preventive actions documented
.in your letter. These actions will be examined during a future inspection of
your licensed program.
.
No reply to this letter is required.
Your cooperation with us is appreciated.
.u
Sincerely,
' *
OriC nal Signed By:
i
Ronald R. Octlamy
Ronald R. Bellamy, Chief
Facilities Radiological Safety
and Safeguards ' Branch
Division of Radiatioa Safety
and Safeguards
,
8807260097 800707
ADDCK 0500033
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0FFICIAL RECORD COPY
RL cf.TZ 87-18 - 0001.0.0 I
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Power Authority of the State
2
JUL 0 71988
of New York
cc:
J. Phillip Bayne, President
Mr. John C. Brons, Executive Vice President
A. Klausmann, Senior Vice President - Appraisal and Compliance Services
R. L. Patch, Quality Assurance Superintendent
George M. Wilverding, Manager Nuclear Safety Evaluation
Gerald C. Goldstein, Assistant General Counsel
R. E. Beedle, Vice President Nuclear Support
S. S. Zulla, Vice President Nuclear Engineering
R. Burns, Vice President Nuclear Operation
Dept. of Public Service, State of New York
State of New York, Department of Law
Public Document Room (POR)
Local Public Document Room (LPDR)
Nucles.r Safety Information Center (NSIC)
NRC Resident Inspector
State of New York
bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, ORMA (w/o encl)
Section Chief, DRP
Robert J. Bores, DRSS
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RI:DRSS
RI:DRSS
Dragoun/ejr
Shanbagg
Bellamy
rf/l)/88
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0FFICIAL RECORD COPY
RL FITZ 87-18 - 0001.1.0
07/06/88
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JUN 15 P88 10:44
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Jerne. A s iu r .e,.e n
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Radford J. Convwa
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& Authority
October 26, 1987
United States Nuclear
.
Regulatory Commission
Attention:
Document Control Desk
Washington, D.C.
20555
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT
DOCKET NO. 50-333
INSPECTION 87-1,8__
1
Gentlemen:
The subject inspection,
an appraisal of our radiation pro-
tection and chemistry programs at the James
A.
FitzPatrick
Nuclear Power Plant, transmitted by your letter dated August
19, 1987, identified a number of strengths and weaknesses in
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this program.
In response to your request contained in the
ec ;2: '. e : r of this :pprair '
cr. atte.cht?-*
Sis le* tar
transmits our response to the weaknesses
identified in the
report.
.
We appreciate the professionalism of your staff in the conduct
of this appraisal.
,
Should you have any questions regarding these matters, please
contact
Eric A. Mulcahey of my staff.
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J. CONVERSE
RJC CJV EAMiemd
E.MulcaheyhNRC)
CC:
A. Luptak (U
T. Martin, Director DRSS, Region I
NRCI-87-18 (File)
Document Control Center
WPO Records Management
-Ohg@
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
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NRC HEALTH PHYSICS APPRAISAL (INSPECTION 87-017)
APPENDIX A - PROGRA!91ATIC WEAKNESSES
FINDING:
1.0.a
Excessive overtime work by the technicians is allowed.
One technician worked
68 days consecutively at 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
Standing Order No. 26 is frequently waived.
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RESPONSE:
In plan'ning for future outages,
sufficient personnel will be
provided to assure that the guidelines of Plant Standing Order
26, "Overtime Policy" can be met.
Any waivers of the overtime
policy
guidelines
will
be
justified
and
authorized
on
an
individual basis rather than for the entire RES technician staff.
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FINDING:
1.0.b
Technicians and first line supervisors are weak in the technical knowledge
although technicians receive 4 days of training every 6 weeks and training
programs are well controlled.
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RESPONSE:
As noted, an excellent training program exists and is expected to
receive accreditation from the national academy in December 1987.
The Authority believes
that the training weaknesses noted stem
from
the
current
need
to
train
technicians
in
both
the
Radiological
and Chemistry disciplines- because
the
technicians
work in both fields.
The Authority expects to discontinue this
practice in the near future.
This will allow technician training
to
be
more
focused
and
effective.
Supervisors
will
attend
selected portions of the technician training program.
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FINDING:
1.0.c
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The position of "Senior Appraisal Specialist - Radiological" has been vacant
50%
of the time since it was created in 1985.
]
RESPONSE:
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The nature and structure of the appraisal function is currently
under review by senior Authority . management as part of a larger
organizationel re-evaluation and is scheduled for completion by
the end of 1987.
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FINDING:
1.0.d
The Exsapt Position Descriptions for Assistant Emergency Plan Coordinator and
Radiation Protection Supervisor are not accurate reflections of position responsi-
bilities.
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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FINDING:
1.0.c
Insufficient numbers of technicians during routine operations prevents effective
cross-training or scheduling flexibility.
RESPONSE:
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Additional contract technicians have been provided for the 1988
budget.
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FINDING:
1.0.f
PP Supervisors are assigned to areas where they have no training or prior
experience (e.g., respiratory protection).
RESPONSE:
The Radiation 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
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The corporate "Tables of Organization" do not accurately reflect the vite
organization.
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RESPONSE:
A revision to the Corporate Table of Organization has been prepared
and submitted to the responsible organization for inclusion in the
1988 revision of this document.
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FINDING:
1.0.h
Insufficient lead time was used when bringing the Corporate Radiological
Engineer on site to assist during outages.
RESPONSE:
This
weakness
was
previously
self-identified
in
cn
internal
critique .of the 1987 refueling outage and will be corrected for
future outages.
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FINDING:
2.0.a
A retraining program developed specifically for supervisors has not been imple-
mented.
RESPONSE:
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A
corporate
wido
training
program
has
been
developed
for
supervisory skills.
attend selected porcionsTechnical skills will be addressed by hav
supervisors
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.
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RESPONSE:
The Author 3 ty does not agree that this is a weakness.
/dequate
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.
RF.SPONSE:
The Authority does not consider the practice of granting credit for
prior training to be a weakness.
Detailed procedures for granting
such credit are contained in Corporate Training Procedures.
These
procedures require that records of satisfactory program completion
be examined and incorporated into Individual Training Files prior
to Branting credit.
The University of the State of New York has evaluated the U.S. Navy
Nuclear power School and granted 32 semester hours of academic
,
credit.
Where appropriate,
advance standing in the technician
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 buh radle:;.
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matteri
however,
such waivers are applied conservatively.
For
example,
credit
is
not
given
for
subjects
such
as
airborne
radioactivity
and
contamination
control,
areas
infrequently
encountered in the naval nuclear power program.
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ANSI qualification is granted only for those ELTs wht aerved in a
lead capacity and have completed applicable portions of the RES
Technician Qualification Standard.
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FINDING:
3.0.b
No program has been developed for the collection and analysis of in-vitro
samples to evaluate intakes which cannot be quantified by in-vivo whole body
counting.
RESPONSE:
A pracadure that contains guidelines for the collection and procsss-
,
ing of in-vitro bionssay samples is under development and will be
complete by December 31, 1987.
This was identified previously by
the plant staff as a program that required upgrading.
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FINDING:
4.0.a
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Management has not been aggressive in impleinenting a chemistry organization
expansion or bringing state-of-the-art equipment or. site into routine operation.
RESPONSE:
Over the past several years, chemistry program improvements have
been
implemented
in
a
deliberate
and
integrated
manner
with
emphasis on efficiency and cost-effectiveness.
Avail 6ble manpower
has been allocated to ensure that the plant chemistry surveillance
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program is not 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 is warranted.
This has been done through
two primary mechanisms:
a comprehensive appraisal of the plant
chemistry program by the Nuclear Steam Supply System (NSSS) vendor
cnd a task force composed of Authority personnel.
Over the past
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four years this task force has been working steadily to resolve
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the numerous recommendations
from this
appraisal
including the
acquisition of new state-of-the-art analytical equipment.
Since this appraisal, a second Chemistry / Radiochemistry Supervisor
end a Chemical Engineer have been added to the plant staff to
facilitate implementation of previously identified upgrades.
At
this time, procedures for the chemistry laboratory instrumentation
reviewed during the appraisal have been formalized and this equip-
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FINDING:
5.0,a
Exposure goals are not challenging or aggressive.
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RESPONSE:
The Authority does not totally agree with this finding.
'de believe
that our goals over the past several years have been reasonable
considering
plant
age,
planned
work
activities
and
economic
considerations.
The Authority ackowledges that the 1986 exposure
goal was easily achievable and actual
exposure was
far below
projections however, as previously explained this occurred due to
the delay 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
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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
chemistry (HWC) is being implemented as another major dose-saving
initiative
to
avoid
replacement
of
the
reactor
recirculation
system piping.
The evaluation of cther processes and technologies
to reduce in-plant radiation buildup is on5oing.
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Aggressive goals have produced a significant reduction in the size
or evncaminatec areas.
vuring 0 67 ene
.t.c
or snese areas nas
been reduced by 30 percent and an aggressive goal of allowing
access to the crescent areau, refuel floor and several other areas
of the plant without
the use of protective clothing has been
established.
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FINDING:
5.0.b
Nsed active participation in ALARA program by work groups and desian engineers.
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RESPONSE:
The corporate Radiological Health and Chemistry (RH&C) Group has
conducted ALARA awareness
training.
This
trainin5,
started in
1985, has' included app'roximately 100 personnel from diverse groups
within
the
Authority s . Corporate
Office.
Additional
training
courses for engineering personnel are under development and are
scheduled
to be
presented
in
the
fourth
guarter of
1987
to
epproximately 170 persons in the corporate starf.
An ALARA Engineering
Course,
taught
by General
Electric,
was
presented to 9 Authority engineers in 1986.
This course in to be
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
that
includes
a
laser
disk-based
video
mapping
system
with
walk-around
capability
to
assist
planners
and
designers
in
svaluating potential inte' ferences in high radiation areas of the
ptauc.
The site ALARA Committee has been and continues to be effective in
maintaining ALARA awareness at the plant level.
Pre-job briefings
and work
reviews,
mock-up
training
and
the
plant
suggestion
program have been effective
in bringing
forth ideas
for
dose
reduction.
Efforts are on-going to involve individual departments
to establish their goals both individual and co'iectively.
Efforts
to
improve
the
involvement
of
engineering
and
site
parsonnel in the ALARA process are always aa on-goin5 Process.
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FINDING:
6.0.a
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The whole body counting f acility is improperly located for use under accident
conditions.
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RESPONSE:
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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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FINDING:
6.0.o
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The calibration facility is too small and crowded.
RESPONSE:
A new administration facility is scheduled to be completed as part
of
the
NYPA capital
improvements
program.
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 801) of survey instruments are out of survice,
RESPONSE:
An
adequate
number
of
calibrated
instruments
are
available to support the radiological protection program.
The
Authority has recognized a problem in obtaining spara parts for
'
certain models of portable survey instruments and has compensated
for this by maintaining a large inventory to ensure an adequate
supply.
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FINDING:
6.0.d
Portal monitors are neither calibrated nor source chicked.
Friskers will not
detect hot particles at observed frisking speeds.
RESPONSE:
The portal monitors referenced in the appraisal have been retired
from sauvice and have been replaced wLth high. sensitivity whole
,
body friskers at egress points from the restricted area.
These
monitors replace manual whole body frisking techniques and have
,
adequate sensitivity to detect hot particles.
The operation and
calibration
of
these
high-sensitivity
whole
bod
friskers
is
controlled by an approved RES Department procedure. y
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The
original portal monitors
are
being
retained
at
the Main
Security
and
Secondary
Access
facilities
to
detect
incoming
radioactive
material
and
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.f
There is a lack of coordinuton of RP responsibilities for equipment purchased
by other groups.
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RESPONSE:
The
equipment
cited
in
the
inspecticn
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
rcdiation work permit and AIARA review processes in addition to
vigilance maintained by radiation protection personnel located at
the
principal
access
point
to
the
restricteo
area
and
in
psrforming plant radiolo81 cal surveillances.
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FINDING:
6.0.g
'the review of routine surveys does not detect technical errors.
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FINDINCr
6.0.h
liigh alpha activity detected during routine surveys is not investigated.
High
volume air samples are not periodically checked for alpha activity.
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RESPONSE:
These two items are the result of a single observation.
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The
surveys that form the basis
for this finding are routina
,
low-volume air samples.
Review activities are prioritized to place
the greatest em?hasis 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
sampling procedure.
This resulted in naturally-occurring redon
daughter activity being counted as unidentified alpha.
The error
has
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anomalous results to radiological supervision has been incorporated
into the procedure.
In adc ition, the need for timely review of
l
routine
survey
results
has
been
emphasized
to
radiological
supervision,
,
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FINDING:
6.0.1
Responsibilities for various facets of the surveillance program is frassented.
1
RESPONSE:
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The
plant
radiological
surveillance
program
is
functionally
delegated
to
those
grou
monitoring activity
(i.e. ps
responsible
for
the
appropriate
air monitoring
is
performed by
the
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 progranssatic weakness since
2
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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