ML20215K163
| ML20215K163 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/12/1987 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 8706250239 | |
| Download: ML20215K163 (2) | |
See also: IR 05000333/1987006
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JUN '12 1987
Docket No. 50-333
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. Power Authority..of 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 No. 50-333/87-06
.This refers to your letter dated May 20, 1987, in response to our letter
dated April 20, 1987.
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Thank you' for , informing us of the corrective and preventive actions documented
in your letter. These actions will be examined during a future in'spection
of your licensed program.
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Your cooperation with us is appreciated.
Sincerely,-
g9d 373
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RAE LL/Uf f/ng_
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Thomas T. Martin, Director
Division of. Radiation Safety
and Safeguards
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L'..W.
Sinclair, President
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LJ. P. Bayne, First Executive Vice President and Chief Operations Officer -
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.A. Klausmann, Vice President - Quality Assurance and Reliability
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R; L. Patch, Quality Assurance Superintendent
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George M. Wilverding, Chairman, Safety Review Committee
Gerald C. Goldstein, Assistant General Counsel
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NRC Licensing Project Manager
-Dept'.' of.Public Service, State of New York
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Public Document Room'(PDR)
Local Public Document Room (LPDR)
Nuclear. Safety Information Center (NSIC)
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LNRC; Resident Inspector
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State'of New York
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James A. FRrPCtrick
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Nuclear Power Plant
PO Box 41
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May 20, 1987
U. S. Nuclear Regulatory Commission
Attn:
Document Control Desk
Washington, D. C. 20555
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT
DOCKET NO. 50-333
INSPECTION NO. 87-06
Gentlemen:
In accordance with the provisions of 10 CFR 2.201, we are submitting our
response to Appendix A Notice of Violation transmitted by your letter
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dated April 20, 1987,- as received by the undersigned on April 27, 1987.
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This refers to the inspection conducted by D. P.'LeQuia of your office
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on March 16-20, 1987 at the James A. FitzPatrick Nuclear Power Plant.
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As a result.of an inspection conducted on March 16 to March 20, 1987,
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and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix
'C), the following violations were identified:
A.
Technical Specification 6.8, " Procedures," requires, in part,
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that procedures be established, implemented, and maintained
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which meet the requirements and recommendations of Regulatory
Guide 1.33, 1972.
Regulatory Guide 1.33, 1972, recommends
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that procedures for restrictions and activities in high
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radiation areas be established.
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Procedure No. 19, " Procedure for Control of Non-Security
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Related Keys Issued to the Operations Department," which
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controls issuance of individual high radiation area access
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keys by shift supervision (SS) requires, in part, in section
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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
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the form, designating his approval for issuing the key;
and
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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 key
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'ist as a reference.
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To:-
U.'S.. Nuclear Regulatory Commission
May,20, 1987
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From s . Radford J. Converse--
Subj ect s . Inspection No. 87-06
Page -2-
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-Contrary to the above,' Shift Sup'ervisor reviews, including.
March 19, 1987, did not identify a missing key, in that a
- controlled key (R-49) was missing, and, had been for an
undetermined period of time.
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Contrary to the above, there were thirty-three (33) instances
where the' Shift Supervisor, or his designated alternate, did
,not initial Form 8.1 authorizing issue of High Radiation Area
and other controlled keys during March 1987.
Contrary to the above, semi-annual inventory (Surveillance No.-
-F-ST-99A, dated 2/16/87) did not account for all required'
keys'
Specifically, one of two required "X1" keys, which
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provide access to the Tip Room (controlled as an area with
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dose rates greater than 1000 mR/hr),'was not accounted for.by.
the inventory.
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This is a Severity Level'IV Violation.
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B,
Technical Specification 6.11-requires,.in'part, that
procedures for personnel radiation protection be prepared'and
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adhered to and that these procedures be formulated to maintain-
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radiation exposures received during operation and maintenance
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as far below the limits specified in 10 CFR.20 as practicable.
.They shall also include contamination control techniques.
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Procedure RPOP-4, " Radiation Work Permit," requires in part,
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in section'4.9.3.d, that the leadman ensures that personnel
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working'on the RWP comply with all dosimetry and protective
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clothing ~ requirements.
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Contrary to the above, at'about 0600 on 1/17/87, the leadman
for RWP 87-345-S did not ensure that'all personnel complied
with the RWP:for cavity work. 'Onel individual signed in on the
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RWP, and performed work in the cavity, and did'not wear
protective plastic suit bottoms required by the RWP. The
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worker was subsequently contaminated.
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This is a Severity Level IV Violation.
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C.
Technical Specification 6.5.2.8, " Audits" states, in part,
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that audits of the performance, training and qualifications of
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the entire facility staff shall be performed at least once per
12 months.
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To:
U. S. Nuclear' Regulatory Commission
May 20, 1987
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From:
Radford J. Converse
Subject:
Inspection No. 87-06
Page
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Procedure SRCP-9 further defines " entire" facility staff to
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mean those facility managerial, supervisory and operational
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personnel having responsibility for and exercising those
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functions required'to assure the conformance of the facility
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operation to provisions contained within the Technical
Specifications and applicable License Conditions.
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Contrary to the above, audits of personnel qualifications, for
audit years 1983-1986, did not include evaluations of
qualifications for Radiation and Environmental Services (RES)
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supervisors below the RES Superintendent.
This is a Severity Level IV Violation.
RESPONSE TO NOTICE OF VIOLATION
A.
The causes of this violation were:
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1)
The key control system contains a very large number of
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keys and does not differentiate between very sensitive
keys and those that are of minor significance.
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2)
The large number of keys are difficult for operations
department personnel, who are on shift, to control with
an accuracy of 100% during high usage time frames (i.e.
outage).
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The short term corrective action included an inventory of all
keys.
The missing X-1 key was subsequently found;
however,
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the missing R-49 key was not.
As a result, the R-49 gate was
re-cored with a new lock.
The administrative requirements of
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the key-control system were reemphasized to the responsible
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operations department personnel and a clerk has been tasked to
check the log on a daily basis for administrative compliance.
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As a long term corrective action, the entire control system
for non-security related keys has been reviewed and a new
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system is being established.
Implementation of the new system
will be accomplished by September 1, 1987.
The major
attributes of the new program include:
a)
Administration by the RES department rather than
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Operations.
This will provide a smaller number oi
individuals who will be directly responsible for program
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administration, thus providing more consistent control.
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To:
U. S.' Nuclear Regulatory Commission
May 20 1987
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'From:
Radford'J. Converse
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Subject:
Inspection No. 87-06
Page
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6)
The establishment of'3 levels of key control. The' level
of control'(inventory, issue of keys, etc.) will vary
with each~ level, so that the most stringent control
conditions will. exist for those a'reas of.most
radiological significance.
For example:
a series.of.
keys will control areas which are greater than 1000
mrem / hour and infrequently accessed,' These keys would be
inventoried at least daily and no master keys issued.
Another series would be for areas where dose rates could
exceed 1000 mrem / hour;
however, access is relatively
frequent'and therefore, radiological' conditions are
known. The last series of keys would be for areas less
than 1000 mrem / hour with well known conditions.
These
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keys would be audited less frequently.
B.
The'cause of this. violation was a misunderstanding by the
leadman and radiation protection personnel over the RWP
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requirement for plastic protective clothing (" plastics") to be
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worn "by JIP direction". During the time frame of the
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misunderstanding, an individual performed work in the reactor
head cavity without " plastics"-although the intent of the RWP
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was to wear " plastics" for this type of work.
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The corrective action for this violation is encompassed by the
corrective actions for the violation sent to the Authority on
April 22, 1987 concerning inspection 87-07.
These actions
include:
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a)
A discussion of the recent radiological incident with the
radiation workers on the plant staff.
Personnel were
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informed that RWP violations would be vigorously pursued'
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and disciplinary actions taken where necessary,
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b)
The development of a pre-job briefing check-off list, and-
requirements for its use. This includes a review of such
radiological control issues as radiological hold points,
requirements of the specific.RWP to be used, radiation
technician assignments and assumptions used in developing
C.
The cause of this violation was an inadequate audit plan which
misinterpreted the need for annually reviewing the
performance, training and qualifications of staff personnel
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below the department superintendent level.
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To:
U. S. Nuclear Regulatory Commission
May 20, 1987
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From:
Radford J. Converse
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Subject:
Inspection No. 87-06
Page
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As indicated in the subject inspection report, full compliance
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was achieved when a satisfactory audit of the RES department
supervisory personnel was performed and a copy provided to the
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inspector on March 25, 1987.
In addition, the audit plan has
been changed to prevent this misinterpretation in the future.
Very truly yours,
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RAD ORD J. CONVERSE
RJC:WF:fah
CC:
NRC Region 1 Office
Attn: Thomas T. Martin
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NRC Resident Inspector
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W. Fernandez
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E. Mulcahey
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D. Lindsey
R. Patch
RMS for Headquarters Distribution: WPO
Document Control Center
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