ML20209D614
| ML20209D614 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/20/1987 |
| From: | Lequia D, Loesch R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20209D582 | List: |
| References | |
| 50-333-87-06, 50-333-87-6, NUDOCS 8704290328 | |
| Download: ML20209D614 (10) | |
See also: IR 05000333/1987006
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-333/87-06
Docket No.
50-333
License No.
Priority
-
Category
C
Licensee:
Power Authority of the State of New York
P. O. Box 41
Lycoming, New York 13093
Facility Name:
James A. FitzPatrick Nuclear Power Plant
Inspection At:
Scriba, New York
Inspection Conducted:
March 16-20, 1987
Inspectors:
MN[-
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D. P. LeQuia, Radiation Specialist
date
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R. M. Loesch, Radiation Specialist
date
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Approved by:
M, N /
M
7
M. Shanbaky, Chief, Facilities 1adiation
dath
1
Protection Section
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Inspection Summary:
Areas Inspected:
Routine, unannounced inspection of the licensee's Radio-
logical Controls Program during an outage.
The following areas were reviewed:
ALARA, internal and external exposure controls, radiation and contaminated
material control, audits and appraisals and the instrument control program.
Results:
Three violations were identified (1 - Failure to audit qualifications
of RES supervision, T.S. 6.5.2.8; 2 - Failure to follow RWP requirements, T.S.
6.11; 3 - Failure to adequately control high radiation area keys, T.S. 6.8).
The licensee was found to have made significant improvements to their radio-
logical instrument control program.
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8704290328 870420
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DETAILS
1.0 Personnel Contacted
1.1 Licensee Personnel
Ouring the course of this inspection, the following personnel were
contacted or interviewed:
- R. Converse, Resident Manager
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- W. Fernandez, Superintendent of Power
- E. Mulcahey, Radiological and Environmental Services Superintendent
- D. Lindsey, Operations Superintendent
- R. Patch, Quality Assurance Superintendent
- V. Walz, Technical Services Superintendent
- R. Baker, Maintenance Superintendent
- R. Wiese, Assistant Maintenance Superintendent
- G. Vargo, Radiological Engineer
- J. Solini, Health Physics General Supervisor
- J. Simplicio, Radiological Specialist, WP0
Other licensee or contractor personnel were also contacted.
1.2 NRC Personnel
- A. Luptak, Senior Resident Inspector
- Denotes attendance at the Exit Meeting held on March 20, 1987.
2.0 Purpose
The purpose of this routine inspection was to review implementation of the
licensee's radiological control program relative to the current refueling
outage. Areas inspected included:
Status of Previously Identified Items
Internal and External Exposure Control
Audits and Appraisals
Radiological Instrument Control Program
3.0 Status of Previously Identified Items
3.1 (Closed) Follow-up Item (50-333/85-30-01):
Licensee to complete
calibration procedures for all instrumentation in use.
Previous
inspections had closed out all instruments with the exception of
those addressed by procedures RTP-4, RTP-14, and RTP-44. The
inspector noted upon review of Revision 1 of the previously men-
tioned procedures that the licensee has addressed the areas of
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calibration and linearity checks in these revised procedures.
Based upon these findings, this item is closed.
3.2 (Closed) Follow-up Item (50-333/86-17-01):
Licensee to determine
scatter characteristics within the irradiation facility.
Inspector
review of memorandums JRES-86-374 (Nov.1986) and JRES-87-006
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(Jan. 1987), and discussions with cognizant personnel determined that
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irradiator backscatter characteristics were evaluated by the licensee.
Based upon the results of the test, the backscatter contribution was
determined to be 2.17 percent and does not represent a significant
difference in the response of shallow (E1) versus deep (E3, E4)
element dose. Based upon these findings, this item is closed.
4.0 Internal / External Exposure Control
The licensee's program relative to internal and external exposure control
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was reviewed against criteria contained in the following:
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Technical Specification 6.11, " Radiation Protection Program"
Technical specification 6.8, " Procedures"
10 CFR 20, " Standards for Protection Against Radiation"
Operations Department Standing Order No.19, Rev. 4, " Procedure
for Control of Non-Security Related Keys Issued to the Operations
Department"
Licensee procedures:
RPOP-4, " Radiation Work Permits"
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RPOP-9, " Radiological Survey Techniques"
Licensee performance relative to these criteria was evaluated by the
following:
Review of air sample records and associated MPC logs
Discussions with cognizant personnel
Review of outage Radiation Work Permits
Inspection of ALARA Review Packages
Audit of the High Radiation Area Key Control Box by the inspector
Independent surveys by the inspector
Tours of the Reactor and Turbine Buildings
Review of documents from Operations Surveillance Test No. F-ST-99A,
dated 2/16/87
Review of the High Radiation Area Key Sign Out Log
Review of survey documents
Review of GE Evaluation EAS 28-0387, dated March 1987, relative to
Lost Parts Analysis of Control Blade Roller
Review of Unusual Radiological Incident Reports
Review of the licensee's Radiation Pratection Manual, Chapter 6
Within the scope of this inspection, the following violations were
identified:
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Technical Specification 6.8, " Procedures," requires, in part, that
procedures be established, implemented, and maintained which meet the
requirements and recommendations of Regulatory Guide 1.33, 1972.
Regu-
latory Guide 1.33, 1972, recommends that procedures for restrictions and
activities in high radiaticn areas be established.
Procedure No. 19, " Procedure for Control of Non-Security Related Keys
Issued to the Operations Department," which controls issuance of individ-
ual high radiation area access keys by shift supervision (SS), requires,
in part, in section 7, that:
1) the on-coming Shift Supervisor reviews
the key log prior to taking the shift to determine if any keys are out
or missing; 2) the SS, or designated alternate, will initial the form,
designating his approval for issuing the key; and 3) semi-annually, the
Operations Superintendent or his designated alternate will perform an
inventory of the non-security related keys using the non-security related
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key list as a reference.
Inspector review of the key log on March 19, 1987, determined that the
Shift Supervisor reviews were inadequate, since they failed to identify
that a controlled key (R-49) was missing.
Inspector review of the key log sheets for March,1987, identified thirty-
three (33) instances of failure by the Shift Supervisor, or his designated
alternate, to initial Form 8.1 authorizing issue of High Radiation Area
and other controlled keys.
Inspector review of the last semi-annual inventory (Surveillance No.
F-ST-99A, dated 2/16/87) found it to be inadequate. Specifically, only
one of two required "X1" keys, that provide access to the Tip Room (which
routinely has dose rates greater than 1000 mR/hr), was accounted for by
the inventory. This deficiency was not recognized by the licensee even
though it underwent three (3) levels of administrative review. Conse-
quently, no corrective actions were taken.
Inspector audit of the key
cabinet on March 19, 1987, found all required "X1" keys to be accounted
for.
The above instances of failure to follow procedures constitute an
apparent violation.
(50-333/87-06-01)
The above matters and their similarity to a previous violation, as
noted in Inspection 85-12, were brought to the licensee's attention.
The licensee stated that lock R-49 would be re-cored and a new key
issued.
In addition, they placed a note in the Shift Supervisor Night
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Order Book to enhance awareness of the key issue requirements of Proce-
dure 00S0-19. The licensee further stated that procedures in this area
would be strengthened.
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Technical Specification 6.11 requires, in part, that procedures for
personnel radiation protection be prepared and adhered to and that these
procedures be formulated to maintain radiation exposures received during
operation and maintenance as far below the limits specified in 10 CFR 20
as practicable. They shall also include contamination control techniques.
Procedure RPOP-4, " Radiation Work Permit," requires, in part, in section
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4.9.3.d, that the leadman ensures that personnel working on the RWP comply
with all dosimetry and protective clothing requirements.
RWP No. 87-345-S, dated 1/17/87, required plastic suits be worn "as per
HP."
The HP Technicians covering the job stated that, as a minimum,
plastic bottoms were required for entry into the Reactor Refueling Cavity.
At about 0600 on 1/17/87, the leadman for RWP 87-345-S did not ensure that
all personnel complied with the RWP. One individual, signed-in on the
RWP, and performed work in the cavity, failed to wear required protective
plastic suit bottoms.
The worker was subsequently contaminated.
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This is an apparent violation (50-333/87-06-02).
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Within the scope of this review, the following additional matters were
discussed with the licensee:
Inspector review of RWPs found that the phrase "as per HP" was
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frequently used to allow flexibility of radiological controls on the
job. However, this practice makes it difficult to reconstruct what
clothing or equipment was required or actually used-for a specific
activity.
Frequently, the licensee is dependent upon the recall
capability of the technician covering the job to determine what
clothing or equipment had been used.
Lack of RWP specificity may
lead to confusion and inconsistencies in implementing radiological
controls.
The inspector discussed this weakness with the licensee,
who stated that they had some awareness of the problem and would
evaluate methods to improve this area.
Inspector tours of the facility found multiple instances where radio-
active material containers were not labeled " CAUTION - Radioactive
Material." Surveys of these containers indicated that 10 CFR 20,
4
Appendix C quantities were not exceeded.
However, the licensee took
timely action to ensure labeling of the containers as a precautionary
measure.
The inspector discussed this matter with the licensee who
stated that they would evaluate methods to strengthen control in this
area.
Procedure 00S0-19 and the Radiation Protection Manual, Chapter 6,
address the methods by which a key is issued to access a High Radi-
ation Area. However, neither of these references specify what
actions must be taken if a key is lost.
The inspector discussed
this matter with the licensee, who stated they would take action
to improve this area.
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5.0 Audits and Appraisals
The licensee's program for Audit and Appraisal of the Radiation Protection
Program was reviewed against criteria contained in the following:
Technical Specification 6.5.2.8, " Audits"
10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power
Plants and Fuel Reprocessing Plant," Criteria XVIII, " Audits"
Regulatory Guide 1.146, " Qualification of Quality Assurance Program
Audit Personnel for Nuclear Power Plants"
ANSI /ASME N45.2.23, 1978, " Qualification of Quality Assurance Program
Audit Personnel for Nuclear Power Plants"
ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant
Personnel"
Performance relative to these criteria was evaluated by:
Review of Safety Review Committee Procedure SRCP-9, Rev. 4, " Audits"
Review of Safety Review Committee Procedure SRCP-18.1, Rev. 3, "SRC
Delegation of Audit Functions"
Review of Appraisal Report [[::JAF-86-01|JAF-86-01]], " Radiological Environmental
Program"
Review of the following Standard Audits:
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No. 519
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No. 521
No. 585
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No. 614
Review of Surveillance Report Audit No. 1139, " Plant Organization /
Staff Qualifications"
Within the scope of this review, the following violation was identified:
Technical Specification 6.5.2.8, " Audits," states, in part, that audits
of the performance, training and qualifications of the entire facility
staff shall be performed at least once per 12 months.
Procedure SRCP-9 further defines " entire" facility staff to mean those
facility managerial, supervisory and operational personnel having
responsibility for and exercising those functions required to assure
the conformance of the facility operation to provisions contained within
the Technical Specifications and applicable License Conditions.
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Audits of personnel qualifications, for audit years 1983-1986, did not
include evaluations of qualifications for Radiation and Environmental
Services (RES) supervisors below the RES Superintendent (RPM).
This is an apparent violation (50-333/87-06-03).
The licensee, upon notification of the above apparent violation, took
timely and aggressive action to audit the qualifications of RES Department
supervisory personnel below the RES Superintendent. Subsequent to this
inspection, a copy of this audit (No. 614, dated 3/23/87) was provided to
the inspector on 3/25/87.
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The following additional weaknesses in the licensee's Audit and Appraisal
Program were identified:
Standard Audits were being performed on a periodic basis. However,
inspector review of these audits found that audit personnel occa-
sionally lacked the technical expertise necessary to properly
evaluate the technical competency of radiological procedures.
Furthermore, the scope of these audits consisted mainly of pro-
cedural compliance. Therefore, these audits were spot-checks
only and not programmatic reviews of the implementation and
quality of Radiation Protection Program.
Inspection Report 86-17 had also identified the above weakness.
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To correct this weakness, the licensee had stated that Corporate
Appraisal staff personnel would be used to augment the techni.11
qualifications of the Quality Assurance (QA) Group during Star, rd
Audits. However, the recent loss of a Senior Appraisal Specialist -
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Radiological from the Appraisal Group weakens their ability to pro-
vide technical support for Standard Audits.
The licensee is actively
seeking a replacement for this position.
The inspector discussed the above weaknesses and the apparent violation
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with the licensee. The licensee stated that the following corrective
actions would be taken:
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To develop a detailed audit plan for the Radiation Prctection Audit
Program.
To audit this plan on a two (2) year basis.
To evaluate the need for audit technical assistance on a case-by-case
basis.
To focus the audit program on implementation and effectiveness of
the established Radiation Protection Program.
To conduct an audit of the qualifications of the RES Supervisory
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staff below the RES Superintendent (RPM) and to review changes to
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the RES staff on a 12 month basis,
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6.0 ALARA
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The inspector reviewed the adequacy, effectiveness and implementation of
the licensee's ALARA program with respect to criteria contained in the
following:
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10 CFR 20.1, " Purpose"
Regulatory Guide 8.8, "Information Relevant to Ensuring the Occupa-
tional Radiation Exposures at Nuclear Power Stations Will Be As Low
As Is Reasonably Achievable" (ALARA)
Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupa-
tional Radiation Exposures As Low As Is Reasanably Achievable"
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Licensee Procedure REP-1, Revision 4, "ALARA Review"
The evaluation of the licensee's performance in this area was based upon
the following:
Discussions with cognizant personnel
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Review of exposure tracking graphs
Evaluation of ALARA Review packages and associated Radiation
Work Permits (RWP)
Review of 1987 ALARA goals
Review of shielding evaluations
Attending a Plant ALARA Committee Meeting
Independent tours and surveys of the Restricted Area
The licensee has implemented and continues to strengthen their ALARA
program. This program includes pre-job, on-the-job and post-job evalu-
ations of activities to control exposure.
Inspector review found that
appropriate procedures were in place to control ALARA work retivities
and that additional equipment has been purchased in support of the
program. This includes a mock-up of a recirculation pump seal package.
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An exposure goal of 950 man-rem has been established for 1987. This goal
has been subdivided into 700 man-rem for the current refueling outage and
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250 man-rem for the remaining coerational year.
Inspector review of
exposure tracking graphs revealed a close correlation between estimated
and actual exposure thus far into the outage.
During inspector review of ALARA packages, it was noted that, while the
package contained valuable information from previous experience, this
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information was not always effectively utilized in preparing subsequent
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ALARA Reviews. The inspector discussed this with the licensee who stated
they would evaluate appropriate methodology to ensure effective use of
available data.
Within the scope of this inspection, no violations were noted.
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7.0 Radiological Instrument Control Program
The licensee's Instrument Control Program was reviewed against criteria
contained in the following:
ANSI N323-1978, "American National Standard Radiation Protection
Instrumentation Test and Calibration"
Radiation Protection Procedures:
RTP-4, "Teletector Operation and Calibration"
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RTP-14, "Model 302B High Level Probe"
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RTP-19, "Eberline Model R0-5A/D Operation and Calibration"
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RTP-44, "3090 Alarming Gamma Monitor"
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Performance relative to the above criteria were evaluated by:
Discussions with cognizant personnel
Review of calibration certificates
Review of Eberline Model 10008 calibration curves
Tours of the survey instrument calibration facility
Review of survey instrument inventory records, and
Review of survey instrument maintenance records
Within the scope of this review, no violations were found.
Licensee instrument control practices were significantly improved from
previous inspections.
Specifically:
A dedicated individual has been assigned to this area. This
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provides better accountability and control of survey instruments.
Inspector review of survey records found them to be significantly
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improved in detail and accuracy.
A method to separate in-service from out-of-service instruments
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has been established.
An instrument issue area has been established to provide for the
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effective control and issuance of instruments.
Inspector review of inventory records found improvement in the
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number of instruments available for use.
The licensee's instrument calibrator has been returned to service.
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8.0 Exit Meeting
The inspector met with licensee management personnel at the conclusion
of this inspection and discussed the findings of the inspection including
apparent violations and program weaknesses.
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