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U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION I | |||
~ | |||
Report No. 50-333/85-12 | |||
Docket No. 50-333 | |||
License No. DPR-59 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: April 22-26, 1985 | |||
Inspectors: kl. N | |||
R. L. Nimitz, Senior Radiation | |||
bbb | |||
date | |||
Specialist | |||
SLd d I4' | |||
K. L. Holsopple, Radittion 5pecialist' | |||
blL!d | |||
date | |||
' Approved by: h m f '/ % 2 6 m 3 'L 4 ////r5 | |||
W. J. Pasciak, Ihief, @WR Radiation datd | |||
Protection Section | |||
~ | |||
Inspection Summary: Inspection on April 22-26, 1985 (Report No. 50-333/85-12). | |||
Areas Inspected: Routine, unannounced inspection of the licensee's Radiolo- | |||
gical Controls Program during an outage. The following areas were reviewed: | |||
organization and staffing; training and qualification; ALARA; external and | |||
internal exposure controls, radiation and contaminated material control; and | |||
radiological controls program implementation. The inspection involved 68 | |||
inspection hours on site by two region-based inspectors. | |||
Results: Two violations were identified in two areas (failure to adhere to | |||
radiation protection procedures in accordance with T.S. 6.11, section 6; and | |||
failure to control high radiation area keys in accordance with T.S. 6.11(A), | |||
Section 6.) The licensee was found to be implementing an effective internal | |||
exposure control program. | |||
pamn mqir | |||
_ | |||
r- . | |||
1 | |||
* | |||
DETAILS | |||
1.0 Individuals Contacted | |||
1.1 Power Authority of the State of New York | |||
*E. Mulcahey, Radiological and Environmental Superintendent | |||
*T. Teifke, Security / Safety Superintendent | |||
*D. Simpson, Trainirg Coordinator | |||
*J. Kerfien, QC Supervisor | |||
*J. Wurouwski, Radiation Protection Training Specialist | |||
*J. J. Kelly, Manager, Radiological Health and Chemistry | |||
*C. J. Gannon, HP General Supervisor | |||
*H. H. Glovier, Resident Manager | |||
*W. Fernandez, Operation Superintendent | |||
*D. Lindsay, Assistant Operation Superintendent | |||
*A. McKeen, Assistant Radiological and Environmental Superintendent | |||
R. Converse, Superintendent of Power i | |||
1.2 Nuclear Regulatory Commission | |||
*L. Doerflein, Senior Resident Inspector | |||
* Denotes those individuals attending the exit meeting on April 26, | |||
1985. | |||
The inspectors also contacted other individuals. | |||
2.0 Purpose of Inspection | |||
The purpose of this routine, unannounced, radiological controls program | |||
inspection was to review the following program elements: | |||
* Organization and Staffing | |||
* Training / Qualification | |||
* ALARA | |||
* Exposure Control: | |||
- | |||
External Exposure Control | |||
- | |||
Internal Exposure Control | |||
a | |||
f | |||
Radioactive and Contaminated Material Control | |||
l | |||
* | |||
Radiological Controls Program Implementation | |||
! | |||
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O' | |||
_ | |||
. | |||
. | |||
# | |||
2 | |||
3.0 Organization and Staffing | |||
The inspector reviewed the Radiological Controls Organization and staffing | |||
with respect to criteria contained in the following: | |||
* Technical Specification 6.2, " Plant Staff Organization" | |||
* | |||
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occu- | |||
pation Radiation Exposures at Nuclear Power Station Will Be As Low | |||
As Reasonably Achievable." | |||
The evaluation of the licensee's performance in the area was based on: | |||
* discussions with cognizant licensee personnel | |||
* | |||
observation of in-field activities | |||
Within the scope of the review, no violations were identified. The | |||
licensee's in place organization was consistent with Technical Specifi- | |||
cation descriptions. Regarding staffing, the licensee appeared to be | |||
adequately staffed to support on going work. | |||
Within the scope of the review, one matter requiring licensee | |||
attention was identified: | |||
Insufficient staffing was utilized to support in Reactor Cavity work on | |||
the evening of April 24, 1985. | |||
Wher, brought to the licensee's attention, additional radiological controls | |||
personnel were assigned to oversee in Reactor Cavity Work. The licensee's | |||
actions on this matter were timely. | |||
4.0 Training and Qualifications | |||
4.1 Radiation Workers | |||
The inspector reviewed the training and qualification of radiation | |||
workers with respect to criteria contained in the following: | |||
* 10 CFR 19.12, " Instructions to Workers" | |||
* | |||
Procedure ITP-3, Revision 6, " General Employee Training" | |||
The evaluation of the licensee's performance in this area was based | |||
on the following: | |||
* | |||
review of inspector selected training documentation including | |||
worker examination grades | |||
a | |||
discussion with cognizant licensee personnel | |||
_ | |||
L | |||
. | |||
. | |||
. | |||
3 | |||
* observation of work in progress | |||
Within the scope of this review, no violations were identified. The | |||
licensee was adequately training and qualifying radiation workers. | |||
4.2 Radiological Control Technicians | |||
The inspector reviewed the training and qualification of contracted | |||
radiological control technicians. The review was with respect to | |||
criteria contained in the following: | |||
* Technical Specification 6.3, " Plant Staff Qualifications" | |||
* | |||
ANSI N18.1, 1971, " Selection and Training of Nuclear Power | |||
Plant Personnel" | |||
The evaluation of the licensee's performance in this area was based | |||
on: | |||
* | |||
review of inspector selected training documentation including | |||
technician examination grades | |||
= observation of on going work including observations of tech- | |||
nician performance on back shifts | |||
* discussion with personnel | |||
Within the scope of this review, no violations were identified. The | |||
licensee was training and qualifying contractor radiological control | |||
technicians consistent with procedures requirements. | |||
Within the scope of this review, the following items for improvement | |||
were identified: | |||
* | |||
Document (as necessary) the training qualification, and retraining | |||
of dosimetry clerical personnel. Currently, no such documentation | |||
is maintained. | |||
* Establish uniform acceptance / evaluation criteria for use in | |||
-evaluating a technician's capabilities relative to performance | |||
of practical factors. Currently no uniform guidance in this | |||
area is established. | |||
Within the scope of this review, the following was noted: | |||
* | |||
Contractor radiation protection personnel, acting in responsible | |||
positions, meet experience requirements specified in Technical | |||
Specifications. | |||
k__ - - _ | |||
_ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ ___ _ ____ _ __ _ _ __ | |||
, | |||
. | |||
4 | |||
5.0 ALARA | |||
The inspector reviewed implementation and adequacy of selected aspects of | |||
the licensee's program for maintaining occupational radiation exposure as | |||
low as reasonably achievable (ALARA). The review was with respect to | |||
criteria contained in the following: | |||
* | |||
Regulatory Guide 8.8, Revision 3, "Information Relevant to Ensuring | |||
that Occupational Exposure At Nuclear Power Plants Will Be As | |||
Low As Is Reasonably Achievable." | |||
* | |||
Regulatory Guide 8.10, Revision 1R, " Operating Philosophy for | |||
Maintaining Occupational Radiation Exposures As Low As Is Reasonably | |||
Achievable." | |||
* Procedure REP 1, "ALARA Review." | |||
The evaluation of the licensee's performance in the area was based on: | |||
* | |||
review of in-field work including Control Rod Drive Removal | |||
* | |||
discussions with cognizant personnel | |||
* review of documentation | |||
Within the scope of this review, the following was noted: | |||
* | |||
the licensee provides generally effective ALARA preplanning for | |||
radiological work | |||
* | |||
the licensee provides generally effective ALARA controls of | |||
on going work | |||
Within .the scope of this review, the following item for improvement was | |||
identified: . | |||
* | |||
include all personnel normally " stationed" at an access control point | |||
into the ALARA review for that particular control point. The licensee | |||
normally includes only one individual (i.e. security guard) in this | |||
ALARA review. The inclusion of these other personnel (e.g. control | |||
point radiological control technicians) would allow inclusion of the | |||
dose sustained by these personnel to be factored into appropriate | |||
control point cost / benefit analyses. As many as 4 individuals were | |||
observed at such control points. | |||
Within the scope of this review, the following violation was identified: | |||
Technical Specification 6.11, " Radiation Protection Program", requires, | |||
in part, that procedures for personnel radiation protection be prepared and | |||
adhered to and that these procedures be formulated to maintain radiation | |||
_ | |||
_ | |||
L - _ - - - - | |||
. - . . - - _ _ _ _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ | |||
. | |||
.. | |||
, | |||
. | |||
5 | |||
exposure received during operation and maintenance as far below the limits | |||
specified in 10 CFR 20 as practicable. | |||
Procedure REP 1, "ALARA Reviews", requires, in part, in section 2.1.6 and | |||
5.2.3, that ALARA reviews for jobs whose man-rem total exceeds 10 man-rem | |||
be approved by the Radiological Engineer, the Radiological and Environ- | |||
mental Services Superintendent, and the Superintendent of Power, as | |||
evidenced by their signatures thereon. | |||
Contrary to the above, as of April 24, 1985, an ALARA review performed | |||
February 17, 1985 for Removal, Transport and Replacement of Control Rod | |||
Drives, which indicated a man-rem total of 12.6 man-rem was not reviewed | |||
as required as evidenced by the lack of signature of the Radiological | |||
Engineer, the Radiological and Environmental Services Superintendent, and | |||
the Superintendent of Power. Work commenced on this task on or before | |||
April 23, 1985. | |||
This item is assigned Item No. 50-333/85-12-01. | |||
6.0 Exposure Controls | |||
6.1 External Exposure Controls | |||
The inspector reviewed the following elements of the licensee's | |||
External Exposure Control Program: | |||
* | |||
posting, barricading, and access control (as necessary) of | |||
radiation and high radiation areas | |||
* | |||
adequacy of radiation surveys made to support on going work | |||
* | |||
adequacy and implemen'.ation of the radiological controls spe- | |||
. | |||
cified on Radiation Work Permits | |||
a | |||
issuance and use of personnel monitoring equipment | |||
The review was with respect to criteria contained in: | |||
* 10 CFR 20, " Standards For Protection Against Radiation" | |||
* Applicable Licensee Procedures | |||
The evaluation of the licensee's performance in this area was based | |||
on: | |||
* | |||
observation by the inspector of on going work during tours of | |||
the facility including tours performed during backshifts | |||
* | |||
independent radiation surveys by the inspector | |||
k, . . | |||
_ _ _ _ _ _ | |||
. | |||
. | |||
6 | |||
* | |||
discussions with licensee personnel | |||
* review of documentation | |||
Within the scope of this review, the following violations were | |||
identified: | |||
1. Technical Specification 6.11, " Radiation Protection Program", | |||
requires, in part, that procedures for personnel radiation pro- | |||
tection be prepared and adhered to and that these procedures | |||
be formulated to maintained radiation exposures received during | |||
operation and maintenance as far below the limits specified in | |||
10 CFR 20 as practicable, | |||
a. Procedure RPOP-4, " Radiation Work Permits", specifies in | |||
part, in section 4.10.2 that it is the leadman's respon- | |||
sibility to assure that all personnel who sign in on a | |||
Radiation Work Permit (RWP) comply with any conditions on | |||
the RWP. | |||
1) RWP No. 3997, dated April 24, 1985 required that hoods | |||
be worn during removal / replacement of IRM/SRM Drytubes | |||
Contrary to the above, at about 6:00 p.m. on April 24, | |||
1985, the leadman for RWP no. 3997 did not assure that | |||
all personnel complied with the RWP. Two individuals, | |||
signed in on the RWP and standing by to perform work, | |||
did not have on hoods. | |||
2) RWP No. 3930-S, dated April 23 1985 required that | |||
hoods be worn in the CRD Rebuild Room when respirators | |||
are worn. | |||
Contrary to the above, at about 2:30 p.m., on April | |||
l 23, 1985, the leadman for RWP No. 3930-S did not | |||
assure that all personnel complied with the RWP. One | |||
individual inside the CRD Rebuild Room, with a respi- | |||
l rator, did not have on a hood. | |||
: b. Procedure RPOP-4, " Radiation Work Permit," requires in part | |||
in section 4.10.4 that if a regular Radiation Work Permit | |||
; (RWP) is needed for more than one shift, the leadman shall | |||
return it to the Radiation Protection Office so that it can | |||
be turned over to the new leadman for acceptance and re- | |||
approval by Radiation Protection. | |||
Contrary to the above, on April 22, 1985 Regular RWP No. | |||
3900 was needed and used for more than one shift; was not | |||
i returned to the Radiation Protection Office for turnover to | |||
l the new leadman for acceptance, and was not reapproved by | |||
l Radiation Protection. | |||
! | |||
. | |||
. | |||
7 | |||
c. RPOP-9, " Radiological Survey Techiques" specifies in part | |||
in section 5.6,-that the general guidance if Table 6 shall | |||
be used in performing radiation work permit surveys. Table | |||
6 requires that a concervative approach to monitoring shall | |||
be taken until it is shown a less conservative approach is | |||
justified. | |||
Contrary to the above, at about 6:00 p.m. on April 24, 1985 | |||
a conservative approach to monitoring a Drytube Cutting | |||
Tool was not taken in that personnel pulled the tool out at | |||
the reactor cavity and were permitted to handle the tool | |||
prior to radiation surveys being made of the tool. A radia- | |||
tion protection technician with a survey meter was about 15 | |||
feet away when the tool was removed, handled, and bagged by | |||
two workers. | |||
This matter was immediately brought to the licensee's | |||
attention who initiated timely action to ensure equipment | |||
is surveyed prior to its handling by personnel and to pro- | |||
vide additional technicians to support on going work on the | |||
Refueling Floor. | |||
The above matters will be followed using Item No. 50-333/ | |||
85-12-01. | |||
When the above matters were brought to the licensee's | |||
attention, the licensee initiated a number of actions to | |||
strengthen oversight and control of on going radiological | |||
work. These actions included the following: | |||
* | |||
The Superintendent of Power met with all appropriate | |||
Radiation Protection Personnel to discuss the need for | |||
personnel to adhere to Radiation Work Permits and Radio- | |||
logical Centrols procedures and were reminded of their | |||
responsibilities in this area. | |||
* The Superintendent of Power directed that once each | |||
normal shift an Radiological and Environmental Ser- | |||
vices (RES) Supervisor will observe the more radio- | |||
logical " sensitive" jobs in progress (tentatively | |||
indicated as those needing ALARA reviews) for purposes | |||
of verifying that procedures are being followed. | |||
Observations are to be reported to the Superintendent | |||
of Power. | |||
* Pre-Job planning of the more " sensitive" jobs were to | |||
be conducted by an RES Supervisor with the Radiation | |||
Protection Technician assigned coverage of the job. | |||
.. | |||
. | |||
8 | |||
* | |||
The Superintendent of Power specified that proper | |||
corrective action, including disciplinary action will | |||
be initiated for individuals found violating proce- | |||
dures. ' | |||
- | |||
The Superintendent of Power issued a memorandum to all | |||
plant workers, relative to the above, on April 25, 1985. | |||
2. Technical Specification 6.8, " Procedures", requires in | |||
part, that procedures be established, implemented, and | |||
maintained which meet the requirements and recommen- | |||
dations of Regulatory Guide 1.33, 1972. Regulatory | |||
Guide 1.33, 1972, recommends that procedures for | |||
restrictions and activities in high radiation areas be | |||
established. In addition, Technical Specification | |||
6.11 (A), "High Radiation Area", requires that, locked | |||
doors be provided to prevent authorized entry into | |||
areas in which the intensity of radiation is greater | |||
than 1,000 millrem/ hour, and that the keys to such | |||
areas be maintained under the administrative control | |||
of the Shift Supervisor on duty and/or the Radio- | |||
logical Environmental Services Superintendent. | |||
a. Contrary to the above, as of April 26, 1985, and | |||
for an undetermined period of time prior to that | |||
cime, 'MR' keys, which provide general (master) ' | |||
access to areas with radiation intensities > | |||
typically less than 10,000 mR/hr were under the | |||
administrative control of the Security and Safety | |||
Group. In addition, the Security Procedure used | |||
to control issuance of the 'MR' keys neither | |||
specified the minimum training and qualification | |||
of personnel needed to obtain an 'MR' key nor | |||
specified the level of authorization (e.g. | |||
. Radiological and Environmental Services Super- | |||
intenent) needed to obtain such a key. | |||
4 | |||
b. Procedure No. 19, " Procedure for Control of Non- | |||
Security Related Keys Issued to the Operations | |||
Department," which controls among other things, | |||
issuance of individual area high radiation area | |||
access keys by shift supervision, requires inpart | |||
in section 7, that the on-coming Shift Supervisor | |||
' reviews the key log prior to taking shift to | |||
determine if any keys are out or missing. | |||
Contrary to the above, on April 23, 1985, neither | |||
the on-coming second shift Shift Supervisor nor | |||
his assistant reviewed the key log prior to | |||
taking shift to determine if any keys are out or | |||
i _ | |||
_ | |||
.. | |||
. | |||
9 | |||
missing. One key was identified missing by the | |||
inspector. | |||
The above matters are assigned Item No. 50-333/ | |||
85-12-04. | |||
The above matters were brought to the licensee's | |||
attention. On April 25, 1985, the Superintendent | |||
of Power issued a memorandum to the Security / | |||
Safety Superintendent providing guidance relative | |||
to issuance of "MR" keys. Also, on April 23, | |||
1985, the licensee initiated action to 1) locate | |||
a missing key from the key locker, and 2) clarify | |||
the guidance contained in Procedure No. 19. The | |||
licensee actions on this matter were timely. | |||
Within the scope of the review, the following additional | |||
matters were identified which should be addressed by the | |||
licensee: | |||
* On April 22, 1985, at about 8:00 p.m., the licensee's | |||
dosimetry personnel did not implement Procedure PDP-1 | |||
relative to completion of all applicable dosimetry | |||
forms. One NRC inspector was not provided all appli- | |||
cable dosimetry forms prior to being provided dost- | |||
metry. Also, dosimetry personnel provided incorrect | |||
allowable exposure limits to the inspectors. | |||
The licensee counseled dosimetry per'sonnel relative to | |||
this matter to preclude recurrence. | |||
* The licensee's Radiation Work Permit Program contained | |||
no guidance relative to revising or modifying the | |||
radiological controls specified on a Radiation Work | |||
Permit. The inspector identified changes made in- | |||
field; Inadequately reviewed or unapproved changes | |||
could degrade the quality of RWP radiological controls. | |||
Licensee representatives indicated guidance in this | |||
area would be established by April 29, 1985. (50-333/ | |||
85-12-02) | |||
* The licensee's Radiation Work Permit Program contained | |||
no guidance relative to performing " intermittent" | |||
surveys of Radiation Work Permit Areas. Inspector | |||
discussions with individual radiological controls | |||
personnel indicated a large variation in the inter- | |||
pretation of " intermittent." | |||
-_. | |||
_. _ | |||
. - _ | |||
f. . | |||
. | |||
10 | |||
. | |||
Licensee representatives indicate general guidance | |||
will be established by April 29, 1985. (50-33/85- | |||
12-03) | |||
6.2 Internal Exposure Controls | |||
The inspector reviewed the following elements of the licensee's | |||
Internal Exposure Control Program: | |||
* ' posting (as necessary) airborne radioactivity areas | |||
e adequacy of airborne radioactivity surveys to support on going | |||
work | |||
* | |||
use of engineering controls in-lieu of providing respiratory | |||
protective equipment to personnel | |||
* proper use of respiratory protection equipment | |||
The review was with respect to criteria contained in: | |||
* 10 CFR 20 " Standards for Protection Against Radiation" | |||
* Applicable Licensee Procedures | |||
The evaluation of the licensee's performance in this area was based | |||
on: | |||
* observation by the inspector of on going work during tours of | |||
the facility including tour performed during backshifts | |||
* discussion with licensee representatives | |||
* review of documentation | |||
Within the scope of the review, no violations were identified. | |||
Within the scope of this review, the following was noted: | |||
* | |||
the licensee made effective use of engineering controls (e.g. | |||
portable ventilation system) to limit airborne radioactivity | |||
and preclude use of respiratory protective equipment | |||
* review of data for the past two years did not indicate an | |||
intake by personnel of airborne radioactivity in excess of | |||
40 MPC-hours. | |||
. | |||
. | |||
11 | |||
7.0 Radioactive and Contaminated Material Control | |||
The inspector reviewed the posting, labeling and control of radioactive | |||
and contaminated material with respect to criteria contained in 10 CFR 20, | |||
" Standards for Protection Against Radiation." ; | |||
The evaluation of the licensee's performance in this area was based on: | |||
* observation by the inspector during tours of the facility including | |||
tours performed during back shifts | |||
* independent radiation surveys performed by the inspector | |||
Within the scope of this review, no violations were identified. The | |||
licensee was implementing an adequate radioactive and contaminated mate- | |||
rial control program. | |||
8.0 Exit | |||
The inspector met with licensee representatives, denoted in section 1 of | |||
the report, on April 20, 1985. The inspector summarized the purpose of, | |||
scope and findings of the inspection. | |||
At no time during this inspection did the inspector provide written | |||
material to the licensee. | |||
. | |||
. | |||
}} | }} |
Latest revision as of 13:09, 23 July 2020
ML20128C697 | |
Person / Time | |
---|---|
Site: | FitzPatrick |
Issue date: | 06/11/1985 |
From: | Holsopple K, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20128C672 | List: |
References | |
50-333-85-12, NUDOCS 8507030658 | |
Download: ML20128C697 (12) | |
See also: IR 05000333/1985012
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
~
Report No. 50-333/85-12
Docket No. 50-333
License No. DPR-59 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: April 22-26, 1985
Inspectors: kl. N
R. L. Nimitz, Senior Radiation
bbb
date
Specialist
SLd d I4'
K. L. Holsopple, Radittion 5pecialist'
blL!d
date
' Approved by: h m f '/ % 2 6 m 3 'L 4 ////r5
W. J. Pasciak, Ihief, @WR Radiation datd
Protection Section
~
Inspection Summary: Inspection on April 22-26, 1985 (Report No. 50-333/85-12).
Areas Inspected: Routine, unannounced inspection of the licensee's Radiolo-
gical Controls Program during an outage. The following areas were reviewed:
organization and staffing; training and qualification; ALARA; external and
internal exposure controls, radiation and contaminated material control; and
radiological controls program implementation. The inspection involved 68
inspection hours on site by two region-based inspectors.
Results: Two violations were identified in two areas (failure to adhere to
radiation protection procedures in accordance with T.S. 6.11, section 6; and
failure to control high radiation area keys in accordance with T.S. 6.11(A),
Section 6.) The licensee was found to be implementing an effective internal
exposure control program.
pamn mqir
_
r- .
1
DETAILS
1.0 Individuals Contacted
1.1 Power Authority of the State of New York
- E. Mulcahey, Radiological and Environmental Superintendent
- T. Teifke, Security / Safety Superintendent
- D. Simpson, Trainirg Coordinator
- J. Kerfien, QC Supervisor
- J. Wurouwski, Radiation Protection Training Specialist
- J. J. Kelly, Manager, Radiological Health and Chemistry
- C. J. Gannon, HP General Supervisor
- H. H. Glovier, Resident Manager
- W. Fernandez, Operation Superintendent
- D. Lindsay, Assistant Operation Superintendent
- A. McKeen, Assistant Radiological and Environmental Superintendent
R. Converse, Superintendent of Power i
1.2 Nuclear Regulatory Commission
- L. Doerflein, Senior Resident Inspector
- Denotes those individuals attending the exit meeting on April 26,
1985.
The inspectors also contacted other individuals.
2.0 Purpose of Inspection
The purpose of this routine, unannounced, radiological controls program
inspection was to review the following program elements:
- Organization and Staffing
- Training / Qualification
- Exposure Control:
-
External Exposure Control
-
Internal Exposure Control
a
f
Radioactive and Contaminated Material Control
l
Radiological Controls Program Implementation
!
{
l
l
O'
_
.
.
2
3.0 Organization and Staffing
The inspector reviewed the Radiological Controls Organization and staffing
with respect to criteria contained in the following:
- Technical Specification 6.2, " Plant Staff Organization"
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occu-
pation Radiation Exposures at Nuclear Power Station Will Be As Low
As Reasonably Achievable."
The evaluation of the licensee's performance in the area was based on:
- discussions with cognizant licensee personnel
observation of in-field activities
Within the scope of the review, no violations were identified. The
licensee's in place organization was consistent with Technical Specifi-
cation descriptions. Regarding staffing, the licensee appeared to be
adequately staffed to support on going work.
Within the scope of the review, one matter requiring licensee
attention was identified:
Insufficient staffing was utilized to support in Reactor Cavity work on
the evening of April 24, 1985.
Wher, brought to the licensee's attention, additional radiological controls
personnel were assigned to oversee in Reactor Cavity Work. The licensee's
actions on this matter were timely.
4.0 Training and Qualifications
4.1 Radiation Workers
The inspector reviewed the training and qualification of radiation
workers with respect to criteria contained in the following:
- 10 CFR 19.12, " Instructions to Workers"
Procedure ITP-3, Revision 6, " General Employee Training"
The evaluation of the licensee's performance in this area was based
on the following:
review of inspector selected training documentation including
worker examination grades
a
discussion with cognizant licensee personnel
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- observation of work in progress
Within the scope of this review, no violations were identified. The
licensee was adequately training and qualifying radiation workers.
4.2 Radiological Control Technicians
The inspector reviewed the training and qualification of contracted
radiological control technicians. The review was with respect to
criteria contained in the following:
- Technical Specification 6.3, " Plant Staff Qualifications"
ANSI N18.1, 1971, " Selection and Training of Nuclear Power
Plant Personnel"
The evaluation of the licensee's performance in this area was based
on:
review of inspector selected training documentation including
technician examination grades
= observation of on going work including observations of tech-
nician performance on back shifts
- discussion with personnel
Within the scope of this review, no violations were identified. The
licensee was training and qualifying contractor radiological control
technicians consistent with procedures requirements.
Within the scope of this review, the following items for improvement
were identified:
Document (as necessary) the training qualification, and retraining
of dosimetry clerical personnel. Currently, no such documentation
is maintained.
- Establish uniform acceptance / evaluation criteria for use in
-evaluating a technician's capabilities relative to performance
of practical factors. Currently no uniform guidance in this
area is established.
Within the scope of this review, the following was noted:
Contractor radiation protection personnel, acting in responsible
positions, meet experience requirements specified in Technical
Specifications.
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5.0 ALARA
The inspector reviewed implementation and adequacy of selected aspects of
the licensee's program for maintaining occupational radiation exposure as
low as reasonably achievable (ALARA). The review was with respect to
criteria contained in the following:
Regulatory Guide 8.8, Revision 3, "Information Relevant to Ensuring
that Occupational Exposure At Nuclear Power Plants Will Be As
Low As Is Reasonably Achievable."
Regulatory Guide 8.10, Revision 1R, " Operating Philosophy for
Maintaining Occupational Radiation Exposures As Low As Is Reasonably
Achievable."
The evaluation of the licensee's performance in the area was based on:
review of in-field work including Control Rod Drive Removal
discussions with cognizant personnel
- review of documentation
Within the scope of this review, the following was noted:
the licensee provides generally effective ALARA preplanning for
radiological work
the licensee provides generally effective ALARA controls of
on going work
Within .the scope of this review, the following item for improvement was
identified: .
include all personnel normally " stationed" at an access control point
into the ALARA review for that particular control point. The licensee
normally includes only one individual (i.e. security guard) in this
ALARA review. The inclusion of these other personnel (e.g. control
point radiological control technicians) would allow inclusion of the
dose sustained by these personnel to be factored into appropriate
control point cost / benefit analyses. As many as 4 individuals were
observed at such control points.
Within the scope of this review, the following violation was identified:
Technical Specification 6.11, " Radiation Protection Program", requires,
in part, that procedures for personnel radiation protection be prepared and
adhered to and that these procedures be formulated to maintain radiation
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exposure received during operation and maintenance as far below the limits
specified in 10 CFR 20 as practicable.
Procedure REP 1, "ALARA Reviews", requires, in part, in section 2.1.6 and
5.2.3, that ALARA reviews for jobs whose man-rem total exceeds 10 man-rem
be approved by the Radiological Engineer, the Radiological and Environ-
mental Services Superintendent, and the Superintendent of Power, as
evidenced by their signatures thereon.
Contrary to the above, as of April 24, 1985, an ALARA review performed
February 17, 1985 for Removal, Transport and Replacement of Control Rod
Drives, which indicated a man-rem total of 12.6 man-rem was not reviewed
as required as evidenced by the lack of signature of the Radiological
Engineer, the Radiological and Environmental Services Superintendent, and
the Superintendent of Power. Work commenced on this task on or before
April 23, 1985.
This item is assigned Item No. 50-333/85-12-01.
6.0 Exposure Controls
6.1 External Exposure Controls
The inspector reviewed the following elements of the licensee's
External Exposure Control Program:
posting, barricading, and access control (as necessary) of
radiation and high radiation areas
adequacy of radiation surveys made to support on going work
adequacy and implemen'.ation of the radiological controls spe-
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cified on Radiation Work Permits
a
issuance and use of personnel monitoring equipment
The review was with respect to criteria contained in:
- 10 CFR 20, " Standards For Protection Against Radiation"
- Applicable Licensee Procedures
The evaluation of the licensee's performance in this area was based
on:
observation by the inspector of on going work during tours of
the facility including tours performed during backshifts
independent radiation surveys by the inspector
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discussions with licensee personnel
- review of documentation
Within the scope of this review, the following violations were
identified:
1. Technical Specification 6.11, " Radiation Protection Program",
requires, in part, that procedures for personnel radiation pro-
tection be prepared and adhered to and that these procedures
be formulated to maintained radiation exposures received during
operation and maintenance as far below the limits specified in
10 CFR 20 as practicable,
a. Procedure RPOP-4, " Radiation Work Permits", specifies in
part, in section 4.10.2 that it is the leadman's respon-
sibility to assure that all personnel who sign in on a
Radiation Work Permit (RWP) comply with any conditions on
the RWP.
1) RWP No. 3997, dated April 24, 1985 required that hoods
be worn during removal / replacement of IRM/SRM Drytubes
Contrary to the above, at about 6:00 p.m. on April 24,
1985, the leadman for RWP no. 3997 did not assure that
all personnel complied with the RWP. Two individuals,
signed in on the RWP and standing by to perform work,
did not have on hoods.
2) RWP No. 3930-S, dated April 23 1985 required that
hoods be worn in the CRD Rebuild Room when respirators
are worn.
Contrary to the above, at about 2:30 p.m., on April
l 23, 1985, the leadman for RWP No. 3930-S did not
assure that all personnel complied with the RWP. One
individual inside the CRD Rebuild Room, with a respi-
l rator, did not have on a hood.
- b. Procedure RPOP-4, " Radiation Work Permit," requires in part
in section 4.10.4 that if a regular Radiation Work Permit
- (RWP) is needed for more than one shift, the leadman shall
return it to the Radiation Protection Office so that it can
be turned over to the new leadman for acceptance and re-
approval by Radiation Protection.
Contrary to the above, on April 22, 1985 Regular RWP No.
3900 was needed and used for more than one shift; was not
i returned to the Radiation Protection Office for turnover to
l the new leadman for acceptance, and was not reapproved by
l Radiation Protection.
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c. RPOP-9, " Radiological Survey Techiques" specifies in part
in section 5.6,-that the general guidance if Table 6 shall
be used in performing radiation work permit surveys. Table
6 requires that a concervative approach to monitoring shall
be taken until it is shown a less conservative approach is
justified.
Contrary to the above, at about 6:00 p.m. on April 24, 1985
a conservative approach to monitoring a Drytube Cutting
Tool was not taken in that personnel pulled the tool out at
the reactor cavity and were permitted to handle the tool
prior to radiation surveys being made of the tool. A radia-
tion protection technician with a survey meter was about 15
feet away when the tool was removed, handled, and bagged by
two workers.
This matter was immediately brought to the licensee's
attention who initiated timely action to ensure equipment
is surveyed prior to its handling by personnel and to pro-
vide additional technicians to support on going work on the
Refueling Floor.
The above matters will be followed using Item No. 50-333/
85-12-01.
When the above matters were brought to the licensee's
attention, the licensee initiated a number of actions to
strengthen oversight and control of on going radiological
work. These actions included the following:
The Superintendent of Power met with all appropriate
Radiation Protection Personnel to discuss the need for
personnel to adhere to Radiation Work Permits and Radio-
logical Centrols procedures and were reminded of their
responsibilities in this area.
- The Superintendent of Power directed that once each
normal shift an Radiological and Environmental Ser-
vices (RES) Supervisor will observe the more radio-
logical " sensitive" jobs in progress (tentatively
indicated as those needing ALARA reviews) for purposes
of verifying that procedures are being followed.
Observations are to be reported to the Superintendent
of Power.
- Pre-Job planning of the more " sensitive" jobs were to
be conducted by an RES Supervisor with the Radiation
Protection Technician assigned coverage of the job.
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The Superintendent of Power specified that proper
corrective action, including disciplinary action will
be initiated for individuals found violating proce-
dures. '
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The Superintendent of Power issued a memorandum to all
plant workers, relative to the above, on April 25, 1985.
2. Technical Specification 6.8, " Procedures", requires in
part, that procedures be established, implemented, and
maintained which meet the requirements and recommen-
dations of Regulatory Guide 1.33, 1972. Regulatory
Guide 1.33, 1972, recommends that procedures for
restrictions and activities in high radiation areas be
established. In addition, Technical Specification 6.11 (A), "High Radiation Area", requires that, locked
doors be provided to prevent authorized entry into
areas in which the intensity of radiation is greater
than 1,000 millrem/ hour, and that the keys to such
areas be maintained under the administrative control
of the Shift Supervisor on duty and/or the Radio-
logical Environmental Services Superintendent.
a. Contrary to the above, as of April 26, 1985, and
for an undetermined period of time prior to that
cime, 'MR' keys, which provide general (master) '
access to areas with radiation intensities >
typically less than 10,000 mR/hr were under the
administrative control of the Security and Safety
Group. In addition, the Security Procedure used
to control issuance of the 'MR' keys neither
specified the minimum training and qualification
of personnel needed to obtain an 'MR' key nor
specified the level of authorization (e.g.
. Radiological and Environmental Services Super-
intenent) needed to obtain such a key.
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b. Procedure No. 19, " Procedure for Control of Non-
Security Related Keys Issued to the Operations
Department," which controls among other things,
issuance of individual area high radiation area
access keys by shift supervision, requires inpart
in section 7, that the on-coming Shift Supervisor
' reviews the key log prior to taking shift to
determine if any keys are out or missing.
Contrary to the above, on April 23, 1985, neither
the on-coming second shift Shift Supervisor nor
his assistant reviewed the key log prior to
taking shift to determine if any keys are out or
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missing. One key was identified missing by the
inspector.
The above matters are assigned Item No. 50-333/
85-12-04.
The above matters were brought to the licensee's
attention. On April 25, 1985, the Superintendent
of Power issued a memorandum to the Security /
Safety Superintendent providing guidance relative
to issuance of "MR" keys. Also, on April 23,
1985, the licensee initiated action to 1) locate
a missing key from the key locker, and 2) clarify
the guidance contained in Procedure No. 19. The
licensee actions on this matter were timely.
Within the scope of the review, the following additional
matters were identified which should be addressed by the
licensee:
- On April 22, 1985, at about 8:00 p.m., the licensee's
dosimetry personnel did not implement Procedure PDP-1
relative to completion of all applicable dosimetry
forms. One NRC inspector was not provided all appli-
cable dosimetry forms prior to being provided dost-
metry. Also, dosimetry personnel provided incorrect
allowable exposure limits to the inspectors.
The licensee counseled dosimetry per'sonnel relative to
this matter to preclude recurrence.
- The licensee's Radiation Work Permit Program contained
no guidance relative to revising or modifying the
radiological controls specified on a Radiation Work
Permit. The inspector identified changes made in-
field; Inadequately reviewed or unapproved changes
could degrade the quality of RWP radiological controls.
Licensee representatives indicated guidance in this
area would be established by April 29, 1985. (50-333/
85-12-02)
- The licensee's Radiation Work Permit Program contained
no guidance relative to performing " intermittent"
surveys of Radiation Work Permit Areas. Inspector
discussions with individual radiological controls
personnel indicated a large variation in the inter-
pretation of " intermittent."
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Licensee representatives indicate general guidance
will be established by April 29, 1985. (50-33/85-
12-03)
6.2 Internal Exposure Controls
The inspector reviewed the following elements of the licensee's
Internal Exposure Control Program:
- ' posting (as necessary) airborne radioactivity areas
e adequacy of airborne radioactivity surveys to support on going
work
use of engineering controls in-lieu of providing respiratory
protective equipment to personnel
- proper use of respiratory protection equipment
The review was with respect to criteria contained in:
- 10 CFR 20 " Standards for Protection Against Radiation"
- Applicable Licensee Procedures
The evaluation of the licensee's performance in this area was based
on:
- observation by the inspector of on going work during tours of
the facility including tour performed during backshifts
- discussion with licensee representatives
- review of documentation
Within the scope of the review, no violations were identified.
Within the scope of this review, the following was noted:
the licensee made effective use of engineering controls (e.g.
portable ventilation system) to limit airborne radioactivity
and preclude use of respiratory protective equipment
- review of data for the past two years did not indicate an
intake by personnel of airborne radioactivity in excess of
40 MPC-hours.
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7.0 Radioactive and Contaminated Material Control
The inspector reviewed the posting, labeling and control of radioactive
and contaminated material with respect to criteria contained in 10 CFR 20,
" Standards for Protection Against Radiation." ;
The evaluation of the licensee's performance in this area was based on:
- observation by the inspector during tours of the facility including
tours performed during back shifts
- independent radiation surveys performed by the inspector
Within the scope of this review, no violations were identified. The
licensee was implementing an adequate radioactive and contaminated mate-
rial control program.
8.0 Exit
The inspector met with licensee representatives, denoted in section 1 of
the report, on April 20, 1985. The inspector summarized the purpose of,
scope and findings of the inspection.
At no time during this inspection did the inspector provide written
material to the licensee.
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