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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/87-18.Copy of Response Resubmitted to Region I on 880620
	ML20151E500
Person / Time
Site:	FitzPatrick
Issue date:	07/07/1988
From:	Bellamy R; 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)
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JUL 0 71989

q Docket No. 50-333

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.

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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.

Sincerely,

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OriCi nal Signed By:

Ronald R. Octlamy

Ronald R. Bellamy, Chief

Facilities Radiological Safety

and Safeguards ' Branch

Division of Radiatioa Safety

and Safeguards

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8807260097 800707

PDR

O ADDCK 0500033 '

PNU ,

0FFICIAL RECORD COPY RL cf.TZ 87-18 - 0001.0.0 I 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 RI:DRSS

'

R

Dragoun/ejr Shanbagg Bellamy

rf/l)/88 }/h/88 }/*1/88

0FFICIAL RECORD COPY RL FITZ 87-18 - 0001.1.0

07/06/88

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Radford J. Convwa

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& Authority

October 26, 1987

JAFP-87-0860

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United States Nuclear

Regulatory Commission

Attention: Document Control Desk

Washington, D.C. 20555

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SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT

DOCKET NO. 50-333

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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 '

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. ,

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Should you have any questions regarding these matters, please ;

contact Eric A. Mulcahey of my staff.

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.DF0 J. CONVERSE

RJC CJV EAMiemd

CC:

E.MulcaheyhNRC)

A. Luptak (U

T. Martin, Director DRSS, Region I

NRCI-87-18 (File)

Document Control Center

WPO Records Management

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.

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RESPONSE: l

The nature and structure of the appraisal function is currently

under review by senior Authority . management as part of a larger

organizationel

the end of 1987.re-evaluation and is scheduled for completion by

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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. l

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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 j

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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.

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RESPONSE:

A corporate wido training program has been developed

supervisory skills. for

supervisors attend selected porcionsTechnical skills will be addressed by hav

program. of the technicians training

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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

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credit. Where appropriate, advance standing in the technician I

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:;. h . . . W .. and .. .. .:i... of . - JD:i :,, ,1:h

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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. -

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:

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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 e

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

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 -

four years this task force has been working steadily to resolve 1

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. j

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 -

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. .

Aggressive goals have produced a significant reduction in the size

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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. l

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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 body

whole accident conditions the Authority will use other facilities

counters in accordance with emergency

agreements and/or contract mobile counters. planning

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FINDING: 6.0.o

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The calibration facility is too small and crowded.

RESPONSE:

A

of new

the administration

NYPA capital facility is scheduled to be completed as part

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 operable, 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

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from sauvice and have been replaced wLth high. sensitivity whole

body friskers at egress points from the restricted area. These

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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 1

The original portal monitors are being retained at

Security and Secondary Access facilities to detect the incoming

Main

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. .

The surveys that form the basis for this finding are routina I ,

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

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add h'.::ul 6 ; '. 2 . . . e sa r e po r . ...g vi

anomalous results to radiological supervision has been incorporated

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routine survey results hasition, the need for timely review of

into the procedure. In adc l

been emphasized to radiological

supervision,

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FINDING: 6.0.1

Responsibilities for various facets of the surveillance program is frassented.

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RESPONSE: '

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The plant radiological surveillance program

delegated to those grou responsible

is functionally

for

(i.e. psair monitoring is performed the appropriate !

monitoring activity by the

respiratory protection group, radiation and contamination surveys

are performed by the radiation protection group and long-term

trending

ing group.) of dose rates is performed by the radiological engineer-

The Authority does not consider the

functional

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assignment of these duties to be a progranssatic weakness since

routine Supervisor.

General results are under the cognizance of the Health Physics

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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ML20151E500

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