IR 05000333/1986021

Insp Rept 50-333/86-21 on 861117-20.No Violations Noted. Major Areas Inspected:Radiological Control Program,Including Gaseous & Liquid Effluents Release Program,Radiological Effluent Tech Specs,Mgt Controls,Audits & Appraisals

ML20212C020
Person / Time
Site:	FitzPatrick
Issue date:	12/18/1986
From:	Davidson B, Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212B995	List: IR 05000333/1986021 ML20212B989
References
TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-333-86-21, NUDOCS 8612290370
Download: ML20212C020 (9)

Text

.

_

-- .

.

.

.

_ U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 86-21 Docket No. 50-333 ,

License No. DPR-59 Priority Category C Licensee: New York Power Authority P.O. Box 41 Lycoming, New York Facility Name: James A. FitzPatrick Nuclear Power Plant Inspection At: Scriba, New York Inspection Conducted: November 17-21, 1986 Inspectors: m sn -

/ /I/

Barry S. pEvidson, Radiation Specialist '- datd

'deMuu Marie T. Hiller, Radiation Specia'ist _

a/<r/a date Approved by: 7/4 NI8ct /et M//

dhte (G WalteY J. Pasciak, Clyfef Effluents Radiation Protection Section Inspection Summary: Inspection on November 17-20, 1986 (Report No. 50-333/86-21)

Areas Inspected: Routine, unannounced inspection of the licensee's radio-logical control program. Areas reviewed included gaseous and liquid effluents release program, RETS implementation, air cleaning systen filter testing, management controls, audits, and appraisal R_esults:

e Of the areas inspected, no violations were identifie PDR G ADOCK 05000333 PDR

_

.

.

DETAILS 1.0 Persons Contacted 1.1 Principal * Licensee Employees R. Converse, Resident Manager R. Patch, QA Superintendent

• W. Fernandez, Superintendent of Power

'

• E. Mulcahey, Radiological and Environmental Service Superintendent

• A. McKeen, Assistant Radiological Environmental Services Superintendent

• B. Gorman, Chemistry General Supervisor

• W. Hamblin, Chemistry Supervisor

• L. Johnston, QA Supervisor

• D. Johnson, Waste Management General Supervisor

• D. Lindsey, Operations Superintendent J. McCarthy, Radiation Protection Supervisor D. Robert, Radiological Waste Supervisor The inspector also interviewed other licensee employees. including members of the chemistry and health physics staf .2 NRC Personnel

• A. Luptak SRI, FitzPatrick

• Denotes those present at exit intervie .0 Status of Previously Identified Items (Closed) Task Action Item II.B.3. The inspector verified that the licensee had made provisions for collecting and analys izing post accident reactor coolant and containment atmosphere samples as required by NUREG-073 (Closed) Task Action Item II.F.1-1.B.2. The inspector verified that the licensee had made provisions for monitoring post accident release pathways as required by NUREG-073 (Closed) Task Action Item II.F.1-2.B.2. The inspector verified that the licensee had addressed particulate and iodine sampling and analysis of post accident effluent pathways as required by NUREG-073 !

(Closed) Task Action Item II.F.1-3. The inspector verified that the licensee had installed two high :ange containment monitors and had pre-pared a method to estimate core damage based on the monitor readings. The inspector also noted that a modification package was developed to improve the locations of the monitors based on a site specific stud _

.

.

'

(Closed) Task Action Item III.D.3.3. The inspector verified that the licensee had made provisions for rapid iodine collection and analysis as required by NUREG-073 (Closed) Unresolved (333/80-01-05): Make modification to stack gas radiation monitor sample line to prevent line plugging. The inspector noted a second sampling probe was installed at a lower elevation to prevent line plugging / freezing. This new sampling probe is used to meet the licensce's Radiological Effluent Technical Specificatians. There had not been any operational problems observed during the monthly surveillance (Closed) Unresolved (333/83-25-04): Complete evaluation and corrective actions regarding resin found in the Tank and Equipment Ventilation System. The inspector verified that the licensee completed the immediate corrective actions as committed during NRC Region I Inspection

'

50-333/83-25. The inspector also verified the continued surveillances, including recording differential pressure measurements once per shift and a visual inspection of the roughing filters on a weekly basis, were being performed. The inspector was informed by the Operations Department that a modification was approved in the 1986 budget to route the resin tank air space to the waste holding tan During a visual inspection conducted by the inspector and the licensee on November 20, 1986, there was some damage observed to the HEPA filter screens, which protect the HEPA filters. The licensee committed to test the HEPA filters by June 30, 1987. The licensee stated there had been no radioactivity increases from this process strea (Closed) Inspector Follow-up Item (333/84-24-04): Evaluate the adequacy of the MCA software to adequately analyze a post-accident mixture of radionuclides. The inspector reviewed the licensee's Post Accident Library to verify the software capability against the licensee's core damage estimate procedur In addition, the inspector noted that the shielded detector had been calibrated for the expected post accident sample geometries (Closed) Inspector Follow-up Item (333/84-24-05): Perform a time and motion study for sampling and analysis of the dissolved gas portion of reactor coolant. The inspector reviewed the licensee's dose assessment study which addressed both sampling and analyzing one dissolved gas sample. The study included conservative assumptions, and it showed that dose contributions were 7 Rem for the extremities and 1.5 Rem for the whole body. These dose contributions, added to the other required PASS samples, were within the GDC 19 criteria of 75R for the extremities and SR for the whole body. The licensee completed the time and motion study on April 21, 1986.

- - - _ . _ - . . _ , , _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - . . _

_ . . _ _ _ _ _ _ _ _ . _ _ _ _ , . . _ _ _ _ _ _ . . . . _ _ _ _ _ , .

.

'

(Closed) Inspector Follow-up Item (333/84-24-07): Improve noble gas effluent monitoring. The licensee evaluated the energy dependence of the noble gas monitor to determine the relationship of the activity release rate as a function of time af ter an accident versus the monitor readin The inspector ' reviewed the licensee's calculation and assumptions which were completed March, 1986. The licensee determined.that the high range noble gas monitor would not have a significant energy dependence extending to 59 days post acciden (Closed) Inspector Follow-up Item (333/84-24/08): Improve particulate /

iodine sampling. The licensee completed a line loss study to determine iodine transmission factors under expected accidents conditions. The result of this study was incorporated into procedure CAP-41 " Post Accident Sample Analysis", Revision 4 on November 5, 1986. The inspector reviewed the empirical study and procedure and determined that appropriate correction factors would be used to improve iodine sampling and analysi The licensee also stated that shielding for the used cartridges was located at the sample statio (Closed) Inspector Follow-up Item (333/84-24-09) Improve Hi-Range Containment monitorii.g. The licensee revised procedure RTP-34,

" Containment Radiation Monitoring - Post Accident" to include site specific response curves for estimating percent of core damage. The inspector also reviewed a draf t modification package (FI-85-73) to relocate one of the detectors to decrease the direct dose rate effect from a recirculation riser. This modification will be completed during the upcoming outgage, which is scheduled to begin on January, 198 (Closed) Inspector Follow-up Item (333/84-24-13): Supply an emergency water source to the PASS station cooler. The inspector determined that the PASS station is supplied by the emergency service water system. The inspector reviewed drawings FM-15A and FM-18C and noted the PASS system was connected to a reliable, category I water sourc (Closed) Violation (333/85-12-04): The licensee did not adhere to Technical Specification 6.8 and 6.11 relative to high radiation area control. The licensee re-cored all of the the locks to prevent inadvertent unauthorized entr The inspector observed that new locks had been installed during a plant inspectio (Closed) Inspector Follow-up Item (333/85-24-02): Update radioactive waste processing procedures and diagrams. The inspector noted that the following procedures had been revised to indicated actual processing operations: F-0P-48C-10, "10-135 Cask", F-0P-48C-9, "14-170 Cask,

"F-0P-49, " Liquid Radwaste System", and F-0P-48" " Solid Radwaste System".

The corresponding drawings were also revised to indicate equiprent not being used to process radioactive wast ~

,

.

'

(Closed) Inspector Follow-up Item (333/86-03-01): Receipt inspection of transport packages not being performed in accordance with procedures. The inspector discussed with the Waste Management General Supervisor the required actions to receipt inspect a transport package. The licensee stated that Quality Assurance was notified prior to the arrival of any transport package, and that the Waste Management Supervisors were designated by Quality Assurance to perform receipt inspections. The licensee stated that the various procedures had been clarified to detail the scope of the inspectio (Closed) Inspector Follow-up Item (333/86-03-03): Ensure documentation associated with the Certificate of Compliance (C of C) are maintaine The inspector reviewed the documentation associated with the C of Cs. The inspector verified the applicable drawings and vendor procedures were available at licensee's facilit (Closed) Inspector Follow-up Item (333/86-12-01): Revise Procedure ESP-2 to Specify biannual audits of each contractor for Radiological Environ-mental Monitoring Program (REMP). The inspector revi ved the subject procedure and determined that it had been recently revised to specify biannual audits for each contractor for the REM (0 pen) Inspector Follow-up Item (333/86-12-02): Review RETS Audits. The inspector reviewed the audit report. The licensee's response to the comprehensive audit will be reviewed during a subsequent inspectio For details see Sections 4 and 6 of this repor (Closed) Inspector Follow-up Iten'(333/85-27-01). Quality Control sample split results and the use of control charts for background data to be reviewed in a future inspection. The inspector reviewed the licensee's control charts and determined that background data was being plotte With regard to QC sample splits, the licensee no longer reviews and trends samples with low levels of radioactivity, because of poor statistic Samples with high activity are plotted on a control chart as percent efficiency instead of net counts. Because this practice is less precise, the licensee agreed to plot not counts instead of efficienc (Closed) Inspector Follow-up Item (333/85-27-02). Licensee to purchase gas calibration standards and recalibrate with this geometry. The inspector determined that appropriate standards had been purchased and calibrations were made. In addition, the correct volumes were now employed:3300 versus 3000 ml formerly use (Closed) Inspector Follow-up Item (333/85-27-03). Licensee to employ appropriate preservation agents for composited samples. The inspector determined that an appropriate quantity of nitric acid was added prior to shipment of samples to vendor laboratories. The inspector discussed addition of preservative throughout the compositing period. The licensee agreed to add nitric acid in the composites as the aliquots accumulate .

• 5 (Closed) Inspector Follow-up Item (333/85-27-04). Licensee to modify sof tware for ef fluent anal) sis and to docurent the validation and verification. The inspector reviewed the changes to the software and its validation and verification anc found ther satisfactor (Closed) Follow-up Item (50-333/85-27-05). During inspection 85-27, selected 1985 Quality Control (QC) data obtained in accordance with Procedure PDP-10, "Whole Body Counter Operation and Calibration," was reviewed It was observed that the licensee did not plot the results of the QC checks on control charts in order to note any trends in QC dat Procedure PCP-10, Revision 1, dated September,1986 has been changed to req; ire plotting the required data on control charts. Radiation control supervision does reviews the control charts, hcwever, this is not required by procedure. The licensee stated, in the future, computer software would be obtained to plot QC data. The software program would include control limits to warn licensee personnel of anomalous data. This item is close .0 Effluent and Process Monitor Calibration and Earveillance Program The inspector reviewed the licuid and gaseous effluent and process monitor calibrations, sampling program, and functional test records to determine compliance with Technical Specifications,'and to determine that the monitors were all calibrated and tested according to the Specifications and preventative maintenance procedures. The inspector reviewed functional and logic test records and results of interlock / release term-ination tests as appropriate. Ttt inspector determined that these sur-veillances were performed according to procedurally established methods, and that frequency requirements were being met. The inspector had no further questions in this are .

4.0 Effluent Release Records The inspector reviewed selected radioactive liquid and gaseous release records, as well as associated procedures and calculations for 1986 to date. The inspector determined that the licensee's Radiological Effluent Technical Specifications (RETS) were implemented on July 1, 1985. The procedures which govern releases indicate that an earnest effort to implement the RETS has been made. The licensee performed an extensive appraisal of the RETS which was reviewed by the inspector. Numerous self-identified concerns were found which indicate that the Offsite Oose Calculation Manual (ODCM) does not always address RETS requirements, provide approved analytical techniques or justify the use of alternatives, and general clarifications in procedures for RETS implemention were neede In addition, some procedures had been icentified which did not ensure timely transfer of information regarding Limiting Conditions of Operation (LCO's). The inspector met with licensee representatives to determine what actions had been made to correct these areas. The appraisal, performed during June of 1986, was formally presented in November 1986 with responses required by January 15, 1987. The licensee representatives

,

O i

• 6 l

provided information that demonstrated improvements in the 00CM for converstor 'a: tors, site specific information, doca-e".ed justification for calculat':nal methods, and pathway analyses Subse;uently, the pro-cedures whicn implement RETS and rely on the 00t.M for methods and bases can be correcte In additien, the inspector reviewed monthly operating data for power level history to determine if LCO requirements were met. Technical Specifica-tion 3.2 requires additional stack sampling when pcwer levels exceed 20%

of rated thermal power in one hour, dose equivalent I-131 increases more than threefold or the noble gas monitor indicates more than a threefold increase after ccrrecting for power level changes. Using the operating history data, the inspector reviewed sampling logs to determine if actions were appropriate. It was found in all instances that increased sampling was made and analyses were timel The inspector requested the licensee to demonstrate its capability in projecting and tracking the doses associated with radioactive effluent release The " Dose Track" program was demonstrated using a mock release for a liquid pathway. In addition, the licensee provided pathway l

verification analysis in which the hand calculated and computer generated values were comparad and found satisfactory. The inspector also reviewed the semi-annual radioactive effluent release reports for the last two reporting periods, which have been generated since the RETS were implemented. The inspector determined that there was no abnormal releases and that all liquid and gaseous releases were within Technical Specification limit .0 In-place Filter Testing The inspector reviewed the licensee's air filtration system testing with regard to Technical Specification requirements 4.7.9.8, " Standby Gas Treatment System" and 4.11. A, " Main Control Room Ventilation". The filter testing and design flow requirements for the Control Room Emergency Ventilatten Air Supply System (CREVASS) was also reviewed against the licensee commitments to NUREG-0737 and proposed Tecnnical Specification The testing was performed by a vendor, whose qualifications had been reviewed previousl The inspector reviewed procedure PSP-6, Revision 4, "SBGTS, CREVASS, and TSCVASS Filter Testing," which references the vendor procedure The most recent revision of the vendor procedures had been reviewed by the Quality Control and Radiological and Environmental Safety Departments. The inspector reviewed the completed surveillance reports for 1985 and 198 Within the scope of this review, no violations were identifie The licensee was informed on November 20, 1986 that the sample for the charcoal removal ef ficiency for one train of the 58GTS had failed during the last test. The licensee entered a limiting The condition of Senior operation, and arranged to replace the adsorben Resident Inspector was reviewing the licensee's actions, a-____--_

,

e

• 7 6.0 Audtts Ihe inspector reviewed audits of the licensee's che91stry and radioactive effluents controls tres cerformed by the Quality Assa-ance and Aporafsal and Compliance Stevices Departments. Specifically, the following audits were reviewed: Idledyne Isotopes Environmental Prog am Audit, Septe car 13, 1333, vd Sectiona; '.;;ra';at R.i;;-t sf RacQiogical/ The Environmental Programs, No. IAF: 96-01, June 2-6 anc 16-17,198 contractor audit encompassed a review of activities germane to the Radiological and Environmental Monitoring Program (REMP) performed on behalf of the licensee. The latter aud't, an extensive review of RETS implementation and 00CM, State Pollution Discharge Elimination System (SPDES) activities and REMP, was recertly presented formally to the licensee. Numerous recommendations were identified in this audit regarding the effective implementation of RETS and SPDES activities. This audit has a response due date of January 15, 1987 and the licensee's response, action plan, and final resolution will be reviewed in a subsequent inspection. In addition, the inspector discussed auditing of contracted vendor activities pertaining to effluents. The licensee had interpreted its audits of the REMP area as having satisfied the requirements for analysis in common with the effluents area. The inspector discussed the importance of oversight of contracted activities and auditing of programs outside the licensee organization to ensure that the scope of audits included chemistry surveillances and that the frequency of audits is sufficient to ensure control of contracted activitie The licensee made a commitment to the inspector that an audit of Teledyne would be made in 1987 and ensure that the scope of the audit would include review of chemistry surveillances, required by Technical Specifications, performed on behalf of the licensee. The inspector stated that this would be reviewed in a sabsequent inspection (333/86-21-01).

7.0 Exit Interview The inspector met with licensee representative (denotedThe in Section 1) at inspector the conclusion of the inspection an November 20, 198 summarized the purpose, scope and findings of the inspection. At no time during this inspection was written material provided to the licensee by the inspecto _ .. _ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _

.

. 7 l

l

!

6.0 Audits The inspector reviewed audits of the licensee's chemistry and radioactive "

ef fluents controls area cerformed by the Quality Assurance and Appraisal and CompItance Stevices Departments. Specifically, the following audits

<

were reviewed: Teledyne Isotopes Environmental Program Audit,

.

'

Septe-cer 13, 1333, and Operational Appraf;al Report of Radiological /

Environmental Programs, No. IAF: 86-01, June 2-6 and 16-17,1986. The l

'

contractor audit encompassed a review of activities germane to the Radiological and Environmental Monitoring Program (REMP) performed on behalf of the license The latter audit, an extensive review of RETS l

implementation and 00CM, State Pollution Olscharge Elimination System r (SPDES) activities and REMP, was recently presented formally to the licensee. Numerous recommendations were identified in this audit regarding the effective implementation of RETS and SPDES activities. This audit has a response due date of January 15, 1987 and the licensev's response, action plan, and final resolution will be reviewed in a subsequent inspection. in addition, the inspector discussed auditing of contracted vendor activities pertaining to effluents. The licensee had interpreted its audits of the REMP area as having satisfied the requirements for analysis in common with the ef fluents area. The inspector discussed the importance of oversight of contracted activities j

and auditing of programs outside the licensee organization to ensure that t

the scope of audits included chemistry surveillances and that the frequency of audits is sufficient to ensure control of contracted activities. The licensee made a commitment to the inspector that an audit of Teledyne would be made in 1987 and ensure that the scope of the audit would include review of chemistry surveillances, required by Technical l Specifications, performed on behalf of the licensee. The inspector stated that this would be reviewed in a subsequent inspection (333/86-21-01).

7.0 Exit Interview The inspector met with licensee representative (denoted in Section 1) at the conclusion of the inspection an November 20, 1986. The inspector summarized tan purpose, scope and findings of the inspection. At no time during this inspection was written material provided to the ifcensee by

,

i the inspecto ..

Sa g