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{{Adams | |||
| number = ML20151E500 | |||
| issue date = 07/07/1988 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/87-18.Copy of Response Resubmitted to Region I on 880620 | |||
| author name = Bellamy R | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = Converse R | |||
| addressee affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK | |||
| docket = 05000333 | |||
| license number = | |||
| contact person = | |||
| document report number = NUDOCS 8807260097 | |||
| title reference date = 10-26-1987 | |||
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | |||
| page count = 2 | |||
}} | |||
See also: [[see also::IR 05000333/1987018]] | |||
=Text= | |||
{{#Wiki_filter:. -. . . . | |||
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JUL 0 71989 | |||
q Docket No. 50-333 | |||
Power Authority.o" the State of New York | |||
James A. FitzPatricK Nuclear Power Plant | |||
ATTN: Mr. Radford J. Converse | |||
Resident'. Manager | |||
P. O. Box 41 | |||
Lycoming, New York 13093 ., | |||
Gentlemen: | |||
. | |||
Subject: Inspection 50-333/87-18 | |||
* | |||
This refers to your letter dated October 26, 1987 in response to o,,r letter | |||
dated August 19, 1987. Based on a telephone discussion between H:. W. Thomas | |||
of this office and Mr. G. Vargo of your staff on June 20, 1988, we understand | |||
that you did not receive a letter from the NRC acknowledging the receipt of | |||
your September 26, 1987 letter. A copy of your response was~ resubmitted to. | |||
Region I on June 20, 1988. | |||
t | |||
Thank you for infurming us of the corrective and preventive actions documented | |||
.in your letter. These actions will be examined during a future inspection of | |||
your licensed program. . | |||
No reply to this letter is required. Your cooperation with us is appreciated. | |||
Sincerely, | |||
.u | |||
' * | |||
OriCi nal Signed By: | |||
Ronald R. Octlamy | |||
Ronald R. Bellamy, Chief | |||
Facilities Radiological Safety | |||
and Safeguards ' Branch | |||
Division of Radiatioa Safety | |||
and Safeguards | |||
, | |||
8807260097 800707 | |||
PDR | |||
O ADDCK 0500033 ' | |||
PNU , | |||
0FFICIAL RECORD COPY RL cf.TZ 87-18 - 0001.0.0 I I | |||
' | |||
. | |||
. . | |||
. . | |||
. | |||
* | |||
Power Authority of the State 2 JUL 0 71988 | |||
of New York | |||
cc: | |||
J. Phillip Bayne, President | |||
Mr. John C. Brons, Executive Vice President | |||
A. Klausmann, Senior Vice President - Appraisal and Compliance Services | |||
R. L. Patch, Quality Assurance Superintendent | |||
George M. Wilverding, Manager Nuclear Safety Evaluation | |||
Gerald C. Goldstein, Assistant General Counsel | |||
R. E. Beedle, Vice President Nuclear Support | |||
S. S. Zulla, Vice President Nuclear Engineering | |||
R. Burns, Vice President Nuclear Operation | |||
Dept. of Public Service, State of New York | |||
State of New York, Department of Law | |||
Public Document Room (POR) | |||
Local Public Document Room (LPDR) | |||
Nucles.r Safety Information Center (NSIC) | |||
NRC Resident Inspector | |||
State of New York | |||
bec w/ enc 1: | |||
Region I Docket Room (with concurrences) | |||
Management Assistant, ORMA (w/o encl) | |||
Section Chief, DRP | |||
Robert J. Bores, DRSS | |||
- - | |||
? | |||
RI:DRSS RI:DRSS RI:DRSS | |||
' | |||
R | |||
Dragoun/ejr Shanbagg Bellamy | |||
rf/l)/88 }/h/88 }/*1/88 | |||
0FFICIAL RECORD COPY RL FITZ 87-18 - 0001.1.0 | |||
07/06/88 | |||
_ _ _ _ . _ _ | |||
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JUN 15 P88 10:44 P02 | |||
l *h8 06/15 10:45 2:002 | |||
.e | |||
Jerne. A s iu r .e,.e n | |||
nweer rower noen, | |||
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ve 342 $d40 | |||
Radford J. Convwa | |||
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& Authority | |||
October 26, 1987 | |||
JAFP-87-0860 | |||
. | |||
United States Nuclear | |||
Regulatory Commission | |||
Attention: Document Control Desk | |||
Washington, D.C. 20555 | |||
l | |||
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT | |||
DOCKET NO. 50-333 | |||
l | |||
INSPECTION 87-1,8__ 1 | |||
Gentlemen: ! | |||
The subject inspection, an appraisal of our radiation pro- | |||
tection and chemistry programs at the James A. FitzPatrick | |||
Nuclear Power Plant, transmitted by your letter dated August | |||
19, 1987, identified a number of strengths and weaknesses in ' | |||
this program. In response to your request contained in the | |||
ec ;2: '. e : r of this :pprair ' cr. atte.cht?-* * Sis le* tar | |||
transmits our response to the weaknesses identified in the | |||
report. . | |||
We appreciate the professionalism of your staff in the conduct | |||
of this appraisal. , | |||
i | |||
Should you have any questions regarding these matters, please ; | |||
contact Eric A. Mulcahey of my staff. | |||
/ 1 | |||
. | |||
4M | |||
.DF0 J. CONVERSE | |||
RJC CJV EAMiemd | |||
CC: | |||
E.MulcaheyhNRC) | |||
A. Luptak (U | |||
T. Martin, Director DRSS, Region I | |||
NRCI-87-18 (File) | |||
Document Control Center | |||
WPO Records Management | |||
CERTIFIED MAIL - RETURN RECEIPT REQUESTED | |||
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JUN 15 *88 10:45 P03 | |||
,' '8ft 06/15 10:46 @oo3 | |||
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NRC HEALTH PHYSICS APPRAISAL (INSPECTION 87-017) | |||
APPENDIX A - PROGRA!91ATIC WEAKNESSES | |||
FINDING: 1.0.a | |||
Excessive overtime work by the technicians is allowed. One technician worked | |||
68 days consecutively at 12 hours per day. Overtime guidance of Plant | |||
Standing Order No. 26 is frequently waived. | |||
. __ | |||
RESPONSE: | |||
In plan'ning for future outages, sufficient personnel will be | |||
provided to assure that the guidelines of Plant Standing Order | |||
26, "Overtime Policy" can be met. Any waivers of the overtime | |||
policy guidelines will be justified and authorized on an | |||
individual basis rather than for the entire RES technician staff. . | |||
I , | |||
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JUN 15 '88 10:45 PO4 | |||
'B8 06/15 10:46 2 004 | |||
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FINDING: 1.0.b | |||
Technicians and first line supervisors are weak in the technical knowledge | |||
although technicians receive 4 days of training every 6 weeks and training | |||
programs are well controlled. | |||
__ | |||
RESPONSE: | |||
As noted, an excellent training program exists and is expected to | |||
receive accreditation from the national academy in December 1987. | |||
The Authority believes that the training weaknesses noted stem | |||
from the current need to train technicians in both the | |||
Radiological and Chemistry disciplines- because the technicians | |||
work in both fields. The Authority expects to discontinue this | |||
practice in the near future. This will allow technician training | |||
to be more focused and effective. Supervisors will attend | |||
selected portions of the technician training program. | |||
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.._ . _ _____ _. . _ . . -- _ - - - - - | |||
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JUN 15 588 10246 P05 l | |||
,' '88 06e15 10 47 2005 | |||
. | |||
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- | |||
FINDING: 1.0.c | |||
) | |||
! | |||
The position of "Senior Appraisal Specialist - Radiological" has been vacant 50% ! | |||
of the time since it was created in 1985. | |||
] | |||
_ l | |||
RESPONSE: l | |||
The nature and structure of the appraisal function is currently | |||
under review by senior Authority . management as part of a larger | |||
organizationel | |||
the end of 1987.re-evaluation and is scheduled for completion by | |||
4 | |||
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1 | |||
- - | |||
JUN 15 '88 10:46 P06 ! | |||
l *B8 06/15 10:48 2 006 | |||
. | |||
* | |||
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1 | |||
FINDING: 1.0.d | |||
The Exsapt Position Descriptions for Assistant Emergency Plan Coordinator and | |||
Radiation Protection Supervisor are not accurate reflections of position responsi- | |||
bilities. | |||
RESPONSE: | |||
The exempt position description for Radiation Protection Super- | |||
visor has been revised. Personnel action has been approved for | |||
promoting the Assistant Emergency Plan Coordinator to Emergency | |||
Plan Coordinator. | |||
. | |||
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I | |||
e | |||
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- | |||
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- - | |||
JUN 15 '88 10:47 P07 | |||
, | |||
*68 06'15 10:48 @ 007 | |||
. | |||
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FINDING: 1.0.c | |||
Insufficient numbers of technicians during routine operations prevents effective | |||
cross-training or scheduling flexibility. | |||
RESPONSE: | |||
i | |||
l | |||
Additional contract technicians have been provided for the 1988 | |||
budget. l | |||
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- | |||
JUN 15 '88 10:47 POS | |||
,' b8 06/15 10:49 2008 | |||
, | |||
.. | |||
FINDING: 1.0.f | |||
PP Supervisors are assigned to areas where they have no training or prior | |||
experience (e.g., respiratory protection). | |||
RESPONSE: | |||
The Radiation Protection Supervisor currently assigned to the | |||
respiratory protection program has had extensive training and | |||
experience in this area. A reassignment of Radiation Protection | |||
Supervisor responsibilities is in progress, however, due to a | |||
misunderstanding, it was implied that this reassignment was | |||
completed at the time of the appraisal before the newly designated | |||
supervisor had received appropriate training in respiratory | |||
protection. | |||
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_ . ... _ -. . - . _- | |||
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.. JUN 15 S88 10:48 P09 | |||
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*88 06/15 10:49 2009 | |||
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FINDING: 1.0.g j | |||
i | |||
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The corporate "Tables of Organization" do not accurately reflect the vite | |||
organization. | |||
, | |||
- | |||
__ | |||
; | |||
RESPONSE: | |||
A revision to the Corporate Table of Organization has been prepared ! | |||
and submitted to the responsible organization for inclusion in the | |||
1988 revision of this document. | |||
; | |||
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JIJN 15 '88 10:48 P10 | |||
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' 88 06/15 10:50 4 010 | |||
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FINDING: 1.0.h | |||
Insufficient lead time was used when bringing the Corporate Radiological | |||
Engineer on site to assist during outages. | |||
RESPONSE: | |||
This weakness was previously self-identified in cn internal | |||
critique .of the 1987 refueling outage and will be corrected for | |||
future outages. | |||
4 | |||
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, _ _ .- ,- -., -- - .- ------ , = - - - - - - - - - - - - - - - ~ ~ ' - ' " ' ~ ^ ' * ~ ~ ~ ~ ~ - | |||
- - - | |||
JUN 15 '88 10:49 P11 | |||
,' 88 06/15 10:50 2011 | |||
. | |||
. | |||
FINDING: 2.0.a | |||
A retraining program developed specifically for supervisors has not been imple- | |||
mented. | |||
._ | |||
RESPONSE: | |||
A corporate wido training program has been developed | |||
supervisory skills. for | |||
supervisors attend selected porcionsTechnical skills will be addressed by hav | |||
program. of the technicians training | |||
, | |||
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- - | |||
JIJil 15 'G8 10: 49 P12 | |||
l '66 OSe15 10:51 2 012 | |||
: | |||
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FINDING: 2.0.b | |||
Training and qualification records are not consolidated to allow verification of | |||
ANSI status. | |||
_. | |||
RESPONSE: | |||
The Author 3 ty does not agree that this is a weakness. /dequate | |||
documentation of personnel training and qualification are | |||
maintained in the Individual Training Files and Personnel Records. | |||
The separation of these records is necessary to ensure adequate | |||
protection of personal data under the New York State Personal | |||
Privacy Act. , | |||
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JUN 15 S88 10:50 P13 | |||
,' '86 06/15 10:51 2013 | |||
FINDING: 2.0.c | |||
Requirements are frequently waived. For example, staff technicians are waived | |||
from certain requirements of Apprentice program and ex-Navy ELT are granted ANSI | |||
status. | |||
RF.SPONSE: | |||
The Authority does not consider the practice of granting credit for | |||
prior training to be a weakness. Detailed procedures for granting | |||
such credit are contained in Corporate Training Procedures. These | |||
procedures require that records of satisfactory program completion | |||
be examined and incorporated into Individual Training Files prior | |||
to Branting credit. | |||
The University of the State of New York has evaluated the U.S. Navy | |||
Nuclear power School and granted 32 semester hours of academic | |||
, | |||
l | |||
credit. Where appropriate, advance standing in the technician I | |||
training program is granted for subjects such as basic courses in | |||
mathematics, thermodynamics, chemistry fundamentals, classical | |||
physics and electricity. Some credit is granted for specific | |||
topics such as corrosion, water purification, sampling techniques | |||
and buh radle:;. h . . . W .. and .. .. .:i... of . - JD:i :,, ,1:h | |||
' | |||
matteri however, such waivers are applied conservatively. For | |||
example, credit is not given for subjects such as airborne | |||
radioactivity and contamination control, areas infrequently | |||
encountered in the naval nuclear power program. - | |||
ANSI qualification is granted only for those ELTs wht aerved in a | |||
lead capacity and have completed applicable portions of the RES | |||
Technician Qualification Standard. | |||
1 | |||
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. _ _ _ . - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . . - _._ ___ | |||
.JUN 15 *88 10:51 | |||
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*88 06/15 10:52 2015 | |||
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FINDING: 3.0.b | |||
No program has been developed for the collection and analysis of in-vitro | |||
samples to evaluate intakes which cannot be quantified by in-vivo whole body | |||
counting. | |||
RESPONSE: | |||
, | |||
A pracadure that contains guidelines for the collection and procsss- | |||
ing of in-vitro bionssay samples is under development and will be | |||
complete by December 31, 1987. This was identified previously by | |||
the plant staff as a program that required upgrading. | |||
, | |||
. . _ . . - . . _ _ , _ . - . , . . _ . . _ - _ _ - _ . _ | |||
- _ _ _. _. - _._ | |||
_ - . | |||
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. JUN 15 '88 10:5'2 | |||
' | |||
P16 | |||
, *88 06/15 10:53 2 016 | |||
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FINDING: 4.0.a e | |||
Management has not been aggressive in impleinenting a chemistry organization | |||
expansion or bringing state-of-the-art equipment or. site into routine operation. | |||
RESPONSE: | |||
Over the past several years, chemistry program improvements have | |||
been implemented in a deliberate and integrated manner with | |||
emphasis on efficiency and cost-effectiveness. Avail 6ble manpower | |||
has been allocated to ensure that the plant chemistry surveillance | |||
program is not compromised in favor of placing new complex analyti- | |||
. | |||
' | |||
cal instrumentation into service. | |||
The Authority has been aggressive in identifying areas where | |||
improvement or upgrading is warranted. This has been done through | |||
two primary mechanisms: a comprehensive appraisal of the plant | |||
chemistry program by the Nuclear Steam Supply System (NSSS) vendor | |||
cnd a task force composed of Authority personnel. Over the past - | |||
four years this task force has been working steadily to resolve 1 | |||
the numerous recommendations from this appraisal including the | |||
acquisition of new state-of-the-art analytical equipment. | |||
Since this appraisal, a second Chemistry / Radiochemistry Supervisor | |||
end a Chemical Engineer have been added to the plant staff to | |||
facilitate implementation of previously identified upgrades. At | |||
this time, procedures for the chemistry laboratory instrumentation | |||
reviewed during the appraisal have been formalized and this equip- - | |||
. . . Is.. . . . ~ :. . . . . .a e . | |||
. | |||
. | |||
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- ' .JUN 15 '88 10:52 | |||
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38 06/15 10:53 2017 | |||
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FINDING: 5.0,a | |||
Exposure goals are not challenging or aggressive. j | |||
RESPONSE: | |||
The Authority does not totally agree with this finding. 'de believe | |||
that our goals over the past several years have been reasonable | |||
considering plant age, planned work activities and economic | |||
considerations. The Authority ackowledges that the 1986 exposure | |||
goal was easily achievable and actual exposure was far below | |||
projections however, as previously explained this occurred due to | |||
the delay of several major work items. The Authority recognized | |||
well before years' end that the goal would easily be achieved, | |||
however,'the Authority's policy is to not adjust established goals | |||
in either direction. | |||
The Authority does recognize the need for further, more dramatic | |||
reductions, and as a result, a chemical decontamination is planned - | |||
in the 1988 refueling outage. This decontamination effort, as ! | |||
stated in the appraisal report, is expected to produce a dose | |||
savings of approximately 300 man-rem. In addition, hydrogen water | |||
chemistry (HWC) is being implemented as another major dose-saving | |||
initiative to avoid replacement of the reactor recirculation | |||
system piping. The evaluation of cther processes and technologies | |||
to reduce in-plant radiation buildup is on5oing. . | |||
Aggressive goals have produced a significant reduction in the size | |||
I | |||
or evncaminatec areas. vuring 0 67 ene .t.c or snese areas nas | |||
been reduced by 30 percent and an aggressive goal of allowing | |||
access to the crescent areau, refuel floor and several other areas | |||
of the plant without the use of protective clothing has been | |||
established. ' | |||
l | |||
i | |||
1 | |||
4 | |||
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l | |||
- | |||
.- .JUN 15 '88 10:53 P18 | |||
, | |||
*88 06/15 10:54 2018 l | |||
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FINDING: 5.0.b | |||
Nsed active participation in ALARA program by work groups and desian engineers. | |||
- - . | |||
RESPONSE: | |||
The corporate Radiological Health and Chemistry (RH&C) Group has | |||
conducted ALARA awareness training. This trainin5, started in | |||
1985, has' included app'roximately 100 personnel from diverse groups | |||
within the Authority s . Corporate Office. Additional training | |||
courses for engineering personnel are under development and are | |||
scheduled to be presented in the fourth guarter of 1987 to | |||
epproximately 170 persons in the corporate starf. | |||
An ALARA Engineering Course, taught by General Electric, was | |||
presented to 9 Authority engineers in 1986. This course in to be | |||
repeated in the fourth quarter of 1987 and is projected to include . | |||
approximately 12 engineers. The corporate RH&C group has also | |||
established an ALARA resource center in the White Plains Office | |||
that includes a laser disk-based video mapping system with | |||
walk-around capability to assist planners and designers in | |||
svaluating potential inte' ferences in high radiation areas of the | |||
ptauc. | |||
The site ALARA Committee has been and continues to be effective in | |||
maintaining ALARA awareness at the plant level. Pre-job briefings | |||
and work reviews, mock-up training and the plant suggestion | |||
program have been effective in bringing forth ideas for dose | |||
reduction. Efforts are on-going to involve individual departments | |||
to establish their goals both individual and co'iectively. ! | |||
Efforts to improve the involvement of engineering and site | |||
parsonnel in the ALARA process are always aa on-goin5 Process. l | |||
i | |||
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. , -_ . _ - , .-- . _ - - . . _. --- _- .- . | |||
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JUN 15 '88 10:54 P19 | |||
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' 86 Me15 10:55 ,g,g | |||
* | |||
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FINDING: 6.0.a | |||
. | |||
The whole body counting f acility is improperly located for use under accident | |||
conditions. ' | |||
-- | |||
__. | |||
_ | |||
RESPONSE: | |||
r | |||
During body | |||
whole accident conditions the Authority will use other facilities | |||
counters in accordance with emergency | |||
agreements and/or contract mobile counters. planning | |||
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JUN 15 "88 10:54 P20 | |||
88'03/15 10:55 | |||
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4 | |||
2020 | |||
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FINDING: 6.0.o | |||
, | |||
The calibration facility is too small and crowded. | |||
RESPONSE: | |||
A | |||
of new | |||
the administration | |||
NYPA capital facility is scheduled to be completed as part | |||
improvements program. The facility will | |||
provide for an imporved calibration area, other alternatives are | |||
under consideration as interim or substitute long-term solutions. | |||
. | |||
4 | |||
' | |||
. | |||
l | |||
s | |||
- _ _ - _ _ - - _ - - . - . - . - | |||
-- - - . , . - - , , _ . . _ . _ . - | |||
. -- ._- .. | |||
_ _ _ - _ _ _ - _ _ | |||
. - - ..JUN 15 '88 10:55 P21 | |||
88 06/15 10:56 | |||
' | |||
, | |||
2021 | |||
. | |||
FINDING: 6.0.c | |||
An excessive number (50 to 801) of survey instruments are out of survice, | |||
RESPONSE: | |||
An adequate number of operable, calibrated instruments are | |||
available to support the radiological protection program. The | |||
Authority has recognized a problem in obtaining spara parts for ' | |||
certain models of portable survey instruments and has compensated | |||
for this by maintaining a large inventory to ensure an adequate | |||
supply. | |||
I | |||
e | |||
l | |||
l | |||
j | |||
. | |||
: | |||
I | |||
i | |||
: | |||
s | |||
, - _ . m - , . , _ . _ , . _ _ , _ . _ . _ _ | |||
_ . _ , , _ ___ _ _ - _ _ _ _ . , , _ _ _ ._m __,y__ - | |||
.. _. . _ _ . _ _ __ . _ - . _ _ - - _ . _ . _ _ _ _ _ . - | |||
* | |||
- - | |||
JUN 15 '88 10:55 P22 | |||
- | |||
'3S 06/15 10:56 2 022 | |||
.. . | |||
. | |||
, | |||
FINDING: 6.0.d | |||
Portal monitors are neither calibrated nor source chicked. Friskers will not | |||
detect hot particles at observed frisking speeds. | |||
RESPONSE: | |||
The portal monitors referenced in the appraisal have been retired | |||
, | |||
from sauvice and have been replaced wLth high. sensitivity whole | |||
body friskers at egress points from the restricted area. These | |||
, | |||
monitors replace manual whole body frisking techniques and have | |||
adequate sensitivity to detect hot particles. The operation and | |||
calibration of these high-sensitivity whole bod friskers is | |||
controlled by an approved RES Department procedure. y 1 | |||
The original portal monitors are being retained at | |||
Security and Secondary Access facilities to detect the incoming | |||
Main | |||
radioactive material and to provide an additional monitoring | |||
capability for personnel exiting the protected area. A procedure | |||
for testing of these monitors will be developed by December 31, | |||
1987. | |||
, | |||
1 | |||
i | |||
4 | |||
. | |||
> | |||
+ | |||
l - - | |||
* | |||
- | |||
JIJN 15 *88 10:56 P24 | |||
,, | |||
Si 06/15 10:57 2 029 | |||
, | |||
. | |||
FINDING: 6.0.f | |||
There is a lack of coordinuton of RP responsibilities for equipment purchased | |||
by other groups. | |||
__ | |||
RESPONSE: | |||
The equipment cited in the inspecticn report represents an | |||
isolated incident. The control of equipment that is intended for | |||
use in the restricted areas of the plant is provided through the | |||
rcdiation work permit and AIARA review processes in addition to | |||
vigilance maintained by radiation protection personnel located at | |||
the principal access point to the restricteo area and in | |||
psrforming plant radiolo81 cal surveillances. - | |||
1 | |||
: | |||
I | |||
i | |||
! | |||
.. | |||
l | |||
, i | |||
1 | |||
4 | |||
- - - - _ . . ,. - | |||
- | |||
* | |||
- | |||
JUN 15 '88 10:57 P25 | |||
*83 06/15 10:58 202o_ | |||
.e* | |||
' | |||
. | |||
* | |||
t | |||
, | |||
FINDING: 6.0.g | |||
'the review of routine surveys does not detect technical errors. | |||
_ | |||
- , . _ | |||
FINDINCr 6.0.h | |||
liigh alpha activity detected during routine surveys is not investigated. High | |||
volume air samples are not periodically checked for alpha activity. | |||
- . | |||
RESPONSE: | |||
These two items are the result of a single observation. . | |||
The surveys that form the basis for this finding are routina I , | |||
low-volume air samples. Review activities are prioritized to place | |||
the greatest em?hasis on the most critical areas such as the | |||
oversight of Radiation Work Permits (RWPs) and routine radiation | |||
and contamination surveys. The high alpha result cited in the | |||
Appraisal Report was due to a technical error in the low-volume air | |||
sampling procedure. This resulted in naturally-occurring redon | |||
daughter activity being counted as unidentified alpha. The error | |||
has ' * :- - | |||
re- :ed ?.: ' | |||
add h'.::ul 6 ; '. 2 . . . e sa r e po r . ...g vi | |||
anomalous results to radiological supervision has been incorporated | |||
, | |||
l | |||
routine survey results hasition, the need for timely review of | |||
into the procedure. In adc l | |||
been emphasized to radiological | |||
: supervision, | |||
l | |||
1 | |||
, | |||
1 | |||
I | |||
- ._ _ . _ _ . _ - .__ _ _ __. _. . _ - | |||
. - . . - -. -. -_. - -- - _ - - . . _ _ | |||
. . . . JUN 15 >88 10:57 P26 | |||
> | |||
, | |||
. | |||
'88 06/15 10:58 8028 | |||
.,, | |||
. | |||
, : | |||
! | |||
* ' | |||
. e | |||
l | |||
, | |||
! c | |||
FINDING: 6.0.1 | |||
: | |||
Responsibilities for various facets of the surveillance program is frassented. | |||
1 | |||
RESPONSE: ' | |||
t | |||
The plant radiological surveillance program | |||
delegated to those grou responsible | |||
is functionally | |||
for | |||
(i.e. psair monitoring is performed the appropriate ! | |||
monitoring activity by the | |||
respiratory protection group, radiation and contamination surveys | |||
are performed by the radiation protection group and long-term | |||
trending | |||
ing group.) of dose rates is performed by the radiological engineer- | |||
The Authority does not consider the | |||
functional | |||
. | |||
' | |||
2 | |||
assignment of these duties to be a progranssatic weakness since | |||
routine Supervisor. | |||
General results are under the cognizance of the Health Physics | |||
Long-term dose rate trend analysis is closely | |||
associated with the ALARA program under the cognizance of the | |||
Radiological Engineering General Supervisor. | |||
f | |||
; . . | |||
* | |||
. | |||
- | |||
1 | |||
; | |||
; | |||
- _ . . - - . . - . - _ . . . - . . - - . . _ . , , . - . - , . . - - . . - . - . - . , . - . - - . - | |||
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i ..- _- .- _-_. __ -- __ ___ _ ._ __ . - - _ _ _ _ _ _ ._ _ _ __ _ _ | |||
}} |
Latest revision as of 23:48, 14 June 2022
ML20151E500 | |
Person / Time | |
---|---|
Site: | FitzPatrick ![]() |
Issue date: | 07/07/1988 |
From: | Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
References | |
NUDOCS 8807260097 | |
Download: ML20151E500 (2) | |
See also: IR 05000333/1987018
Text
. -. . . .
' ,. ~ ,.
1 j
'i
JUL 0 71989
q Docket No. 50-333
Power Authority.o" the State of New York
James A. FitzPatricK Nuclear Power Plant
ATTN: Mr. Radford J. Converse
Resident'. Manager
P. O. Box 41
Lycoming, New York 13093 .,
Gentlemen:
.
Subject: Inspection 50-333/87-18
This refers to your letter dated October 26, 1987 in response to o,,r letter
dated August 19, 1987. Based on a telephone discussion between H:. W. Thomas
of this office and Mr. G. Vargo of your staff on June 20, 1988, we understand
that you did not receive a letter from the NRC acknowledging the receipt of
your September 26, 1987 letter. A copy of your response was~ resubmitted to.
Region I on June 20, 1988.
t
Thank you for infurming us of the corrective and preventive actions documented
.in your letter. These actions will be examined during a future inspection of
your licensed program. .
No reply to this letter is required. Your cooperation with us is appreciated.
Sincerely,
.u
' *
OriCi nal Signed By:
Ronald R. Octlamy
Ronald R. Bellamy, Chief
Facilities Radiological Safety
and Safeguards ' Branch
Division of Radiatioa Safety
and Safeguards
,
8807260097 800707
O ADDCK 0500033 '
PNU ,
0FFICIAL RECORD COPY RL cf.TZ 87-18 - 0001.0.0 I I
'
.
. .
. .
.
Power Authority of the State 2 JUL 0 71988
of New York
cc:
J. Phillip Bayne, President
Mr. John C. Brons, Executive Vice President
A. Klausmann, Senior Vice President - Appraisal and Compliance Services
R. L. Patch, Quality Assurance Superintendent
George M. Wilverding, Manager Nuclear Safety Evaluation
Gerald C. Goldstein, Assistant General Counsel
R. E. Beedle, Vice President Nuclear Support
S. S. Zulla, Vice President Nuclear Engineering
R. Burns, Vice President Nuclear Operation
Dept. of Public Service, State of New York
State of New York, Department of Law
Public Document Room (POR)
Local Public Document Room (LPDR)
Nucles.r Safety Information Center (NSIC)
NRC Resident Inspector
State of New York
bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, ORMA (w/o encl)
Section Chief, DRP
Robert J. Bores, DRSS
- -
?
RI:DRSS RI:DRSS RI:DRSS
'
R
Dragoun/ejr Shanbagg Bellamy
rf/l)/88 }/h/88 }/*1/88
0FFICIAL RECORD COPY RL FITZ 87-18 - 0001.1.0
07/06/88
_ _ _ _ . _ _
-
-
-
-
JUN 15 P88 10:44 P02
l *h8 06/15 10:45 2:002
.e
Jerne. A s iu r .e,.e n
nweer rower noen,
.
ec w a
.- u.:3, m *., c m i usa
ve 342 $d40
Radford J. Convwa
g gggg7 % . .n v ,e.,,,
& Authority
October 26, 1987
.
United States Nuclear
Regulatory Commission
Attention: Document Control Desk
Washington, D.C. 20555
l
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT
DOCKET NO. 50-333
l
INSPECTION 87-1,8__ 1
Gentlemen: !
The subject inspection, an appraisal of our radiation pro-
tection and chemistry programs at the James A. FitzPatrick
Nuclear Power Plant, transmitted by your letter dated August
19, 1987, identified a number of strengths and weaknesses in '
this program. In response to your request contained in the
ec ;2: '. e : r of this :pprair ' cr. atte.cht?-* * Sis le* tar
transmits our response to the weaknesses identified in the
report. .
We appreciate the professionalism of your staff in the conduct
of this appraisal. ,
i
Should you have any questions regarding these matters, please ;
contact Eric A. Mulcahey of my staff.
/ 1
.
4M
.DF0 J. CONVERSE
RJC CJV EAMiemd
CC:
E.MulcaheyhNRC)
A. Luptak (U
T. Martin, Director DRSS, Region I
NRCI-87-18 (File)
Document Control Center
WPO Records Management
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
-Ohg@
. -
.- . _- .. .. .- . . _ .
-
-
-
JUN 15 *88 10:45 P03
,' '8ft 06/15 10:46 @oo3
-
.
.
.
.
NRC HEALTH PHYSICS APPRAISAL (INSPECTION 87-017)
APPENDIX A - PROGRA!91ATIC WEAKNESSES
FINDING: 1.0.a
Excessive overtime work by the technicians is allowed. One technician worked
68 days consecutively at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day. Overtime guidance of Plant
Standing Order No. 26 is frequently waived.
. __
RESPONSE:
In plan'ning for future outages, sufficient personnel will be
provided to assure that the guidelines of Plant Standing Order
26, "Overtime Policy" can be met. Any waivers of the overtime
policy guidelines will be justified and authorized on an
individual basis rather than for the entire RES technician staff. .
I ,
l
1
,
l
.
-- ,_ ,, , , . - - _. - . , . , . - - . - . . - . , , - - _ , - - , . .
. _ .
-
'
-
-
-
JUN 15 '88 10:45 PO4
'B8 06/15 10:46 2 004
.
.
'
i
i
FINDING: 1.0.b
Technicians and first line supervisors are weak in the technical knowledge
although technicians receive 4 days of training every 6 weeks and training
programs are well controlled.
__
RESPONSE:
As noted, an excellent training program exists and is expected to
receive accreditation from the national academy in December 1987.
The Authority believes that the training weaknesses noted stem
from the current need to train technicians in both the
Radiological and Chemistry disciplines- because the technicians
work in both fields. The Authority expects to discontinue this
practice in the near future. This will allow technician training
to be more focused and effective. Supervisors will attend
selected portions of the technician training program.
.
. e
l
!
l
l
l
.._ . _ _____ _. . _ . . -- _ - - - - -
-
-
-
.
JUN 15 588 10246 P05 l
,' '88 06e15 10 47 2005
.
.
.
-
FINDING: 1.0.c
)
!
The position of "Senior Appraisal Specialist - Radiological" has been vacant 50% !
of the time since it was created in 1985.
]
_ l
RESPONSE: l
The nature and structure of the appraisal function is currently
under review by senior Authority . management as part of a larger
organizationel
the end of 1987.re-evaluation and is scheduled for completion by
4
!
i
f
!
l
4
- . . . - . .
_. , _ ~ _ , - , _ _ _ _ _ _ _ . _ _ . , _ , , , .._._4
.
1
- -
JUN 15 '88 10:46 P06 !
l *B8 06/15 10:48 2 006
.
.
l
1
FINDING: 1.0.d
The Exsapt Position Descriptions for Assistant Emergency Plan Coordinator and
Radiation Protection Supervisor are not accurate reflections of position responsi-
bilities.
RESPONSE:
The exempt position description for Radiation Protection Super-
visor has been revised. Personnel action has been approved for
promoting the Assistant Emergency Plan Coordinator to Emergency
Plan Coordinator.
.
.
I
e
. _ . -
_ _ _ . _ _ - . . . . _ .__
.
_..__, . _ . . _ . . _ _ _ . . . . _
._. ..
-
- -
JUN 15 '88 10:47 P07
,
- 68 06'15 10:48 @ 007
.
,
.
FINDING: 1.0.c
Insufficient numbers of technicians during routine operations prevents effective
cross-training or scheduling flexibility.
RESPONSE:
i
l
Additional contract technicians have been provided for the 1988
budget. l
'
.
e
0
P
s
- -
-v r.--- , . _ - , _ - _ . . , , . . . . . . . , , . _ . . , , . , - . , . . . . , - , ,, ,.% ,_, , , , . ._ , ..,_.y... ,,
._
-
.
-
JUN 15 '88 10:47 POS
,' b8 06/15 10:49 2008
,
..
FINDING: 1.0.f
PP Supervisors are assigned to areas where they have no training or prior
experience (e.g., respiratory protection).
RESPONSE:
The Radiation Protection Supervisor currently assigned to the
respiratory protection program has had extensive training and
experience in this area. A reassignment of Radiation Protection
Supervisor responsibilities is in progress, however, due to a
misunderstanding, it was implied that this reassignment was
completed at the time of the appraisal before the newly designated
supervisor had received appropriate training in respiratory
protection.
.
l
l
l
_ . ... _ -. . - . _-
_.
I- '
.. JUN 15 S88 10:48 P09
,
- 88 06/15 10:49 2009
t
.
.
. ,
i
FINDING: 1.0.g j
i
I
The corporate "Tables of Organization" do not accurately reflect the vite
organization.
,
-
__
RESPONSE:
A revision to the Corporate Table of Organization has been prepared !
and submitted to the responsible organization for inclusion in the
1988 revision of this document.
1
l
!
l
!
,
.
l
l
l
1
. !
I
l
I
,
l
. _. - . . - . . ._. -
!
'-
'
- -
.
JIJN 15 '88 10:48 P10
,,
' 88 06/15 10:50 4 010
.
.'
.
FINDING: 1.0.h
Insufficient lead time was used when bringing the Corporate Radiological
Engineer on site to assist during outages.
RESPONSE:
This weakness was previously self-identified in cn internal
critique .of the 1987 refueling outage and will be corrected for
future outages.
4
a
!
, _ _ .- ,- -., -- - .- ------ , = - - - - - - - - - - - - - - - ~ ~ ' - ' " ' ~ ^ ' * ~ ~ ~ ~ ~ -
- - -
JUN 15 '88 10:49 P11
,' 88 06/15 10:50 2011
.
.
FINDING: 2.0.a
A retraining program developed specifically for supervisors has not been imple-
mented.
._
RESPONSE:
A corporate wido training program has been developed
supervisory skills. for
supervisors attend selected porcionsTechnical skills will be addressed by hav
program. of the technicians training
,
e
i
i
)
1
!
l
l
- . - .
_ _ .. ._ _ _ . . - . . . _ _ __ __ '
- -
JIJil 15 'G8 10: 49 P12
l '66 OSe15 10:51 2 012
..
.
FINDING: 2.0.b
Training and qualification records are not consolidated to allow verification of
ANSI status.
_.
RESPONSE:
The Author 3 ty does not agree that this is a weakness. /dequate
documentation of personnel training and qualification are
maintained in the Individual Training Files and Personnel Records.
The separation of these records is necessary to ensure adequate
protection of personal data under the New York State Personal
Privacy Act. ,
!
.
9
!
l
i
I
. -
-- .- - - - --, -.- -
. - - .
- -
JUN 15 S88 10:50 P13
,' '86 06/15 10:51 2013
FINDING: 2.0.c
Requirements are frequently waived. For example, staff technicians are waived
from certain requirements of Apprentice program and ex-Navy ELT are granted ANSI
status.
RF.SPONSE:
The Authority does not consider the practice of granting credit for
prior training to be a weakness. Detailed procedures for granting
such credit are contained in Corporate Training Procedures. These
procedures require that records of satisfactory program completion
be examined and incorporated into Individual Training Files prior
to Branting credit.
The University of the State of New York has evaluated the U.S. Navy
Nuclear power School and granted 32 semester hours of academic
,
l
credit. Where appropriate, advance standing in the technician I
training program is granted for subjects such as basic courses in
mathematics, thermodynamics, chemistry fundamentals, classical
physics and electricity. Some credit is granted for specific
topics such as corrosion, water purification, sampling techniques
and buh radle:;. h . . . W .. and .. .. .:i... of . - JD:i :,, ,1:h
'
matteri however, such waivers are applied conservatively. For
example, credit is not given for subjects such as airborne
radioactivity and contamination control, areas infrequently
encountered in the naval nuclear power program. -
ANSI qualification is granted only for those ELTs wht aerved in a
lead capacity and have completed applicable portions of the RES
Technician Qualification Standard.
1
l
i
4
. _ _ _ . - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . . - _._ ___
.JUN 15 *88 10:51
- '
. P15
,
,,
- 88 06/15 10:52 2015
l-
t
FINDING: 3.0.b
No program has been developed for the collection and analysis of in-vitro
samples to evaluate intakes which cannot be quantified by in-vivo whole body
counting.
RESPONSE:
,
A pracadure that contains guidelines for the collection and procsss-
ing of in-vitro bionssay samples is under development and will be
complete by December 31, 1987. This was identified previously by
the plant staff as a program that required upgrading.
,
. . _ . . - . . _ _ , _ . - . , . . _ . . _ - _ _ - _ . _
- _ _ _. _. - _._
_ - .
- . - . . .
. JUN 15 '88 10:5'2
'
P16
, *88 06/15 10:53 2 016
'
!
FINDING: 4.0.a e
Management has not been aggressive in impleinenting a chemistry organization
expansion or bringing state-of-the-art equipment or. site into routine operation.
RESPONSE:
Over the past several years, chemistry program improvements have
been implemented in a deliberate and integrated manner with
emphasis on efficiency and cost-effectiveness. Avail 6ble manpower
has been allocated to ensure that the plant chemistry surveillance
program is not compromised in favor of placing new complex analyti-
.
'
cal instrumentation into service.
The Authority has been aggressive in identifying areas where
improvement or upgrading is warranted. This has been done through
two primary mechanisms: a comprehensive appraisal of the plant
chemistry program by the Nuclear Steam Supply System (NSSS) vendor
cnd a task force composed of Authority personnel. Over the past -
four years this task force has been working steadily to resolve 1
the numerous recommendations from this appraisal including the
acquisition of new state-of-the-art analytical equipment.
Since this appraisal, a second Chemistry / Radiochemistry Supervisor
end a Chemical Engineer have been added to the plant staff to
facilitate implementation of previously identified upgrades. At
this time, procedures for the chemistry laboratory instrumentation
reviewed during the appraisal have been formalized and this equip- -
. . . Is.. . . . ~ :. . . . . .a e .
.
.
- --- -,
, , - , - ..--- ,-.--__ .
,e--,.,__ ,.- e,,.,, n-n_.--~ +.,_--,,,n
1
1
- ' .JUN 15 '88 10:52
P17 , j
,
38 06/15 10:53 2017
.
l
'
FINDING: 5.0,a
Exposure goals are not challenging or aggressive. j
RESPONSE:
The Authority does not totally agree with this finding. 'de believe
that our goals over the past several years have been reasonable
considering plant age, planned work activities and economic
considerations. The Authority ackowledges that the 1986 exposure
goal was easily achievable and actual exposure was far below
projections however, as previously explained this occurred due to
the delay of several major work items. The Authority recognized
well before years' end that the goal would easily be achieved,
however,'the Authority's policy is to not adjust established goals
in either direction.
The Authority does recognize the need for further, more dramatic
reductions, and as a result, a chemical decontamination is planned -
in the 1988 refueling outage. This decontamination effort, as !
stated in the appraisal report, is expected to produce a dose
savings of approximately 300 man-rem. In addition, hydrogen water
chemistry (HWC) is being implemented as another major dose-saving
initiative to avoid replacement of the reactor recirculation
system piping. The evaluation of cther processes and technologies
to reduce in-plant radiation buildup is on5oing. .
Aggressive goals have produced a significant reduction in the size
I
or evncaminatec areas. vuring 0 67 ene .t.c or snese areas nas
been reduced by 30 percent and an aggressive goal of allowing
access to the crescent areau, refuel floor and several other areas
of the plant without the use of protective clothing has been
established. '
l
i
1
4
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.- .JUN 15 '88 10:53 P18
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FINDING: 5.0.b
Nsed active participation in ALARA program by work groups and desian engineers.
- - .
RESPONSE:
The corporate Radiological Health and Chemistry (RH&C) Group has
conducted ALARA awareness training. This trainin5, started in
1985, has' included app'roximately 100 personnel from diverse groups
within the Authority s . Corporate Office. Additional training
courses for engineering personnel are under development and are
scheduled to be presented in the fourth guarter of 1987 to
epproximately 170 persons in the corporate starf.
An ALARA Engineering Course, taught by General Electric, was
presented to 9 Authority engineers in 1986. This course in to be
repeated in the fourth quarter of 1987 and is projected to include .
approximately 12 engineers. The corporate RH&C group has also
established an ALARA resource center in the White Plains Office
that includes a laser disk-based video mapping system with
walk-around capability to assist planners and designers in
svaluating potential inte' ferences in high radiation areas of the
ptauc.
The site ALARA Committee has been and continues to be effective in
maintaining ALARA awareness at the plant level. Pre-job briefings
and work reviews, mock-up training and the plant suggestion
program have been effective in bringing forth ideas for dose
reduction. Efforts are on-going to involve individual departments
to establish their goals both individual and co'iectively. !
Efforts to improve the involvement of engineering and site
parsonnel in the ALARA process are always aa on-goin5 Process. l
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JUN 15 '88 10:54 P19
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' 86 Me15 10:55 ,g,g
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FINDING: 6.0.a
.
The whole body counting f acility is improperly located for use under accident
conditions. '
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_
RESPONSE:
r
During body
whole accident conditions the Authority will use other facilities
counters in accordance with emergency
agreements and/or contract mobile counters. planning
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JUN 15 "88 10:54 P20
88'03/15 10:55
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FINDING: 6.0.o
,
The calibration facility is too small and crowded.
RESPONSE:
A
of new
the administration
NYPA capital facility is scheduled to be completed as part
improvements program. The facility will
provide for an imporved calibration area, other alternatives are
under consideration as interim or substitute long-term solutions.
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. - - ..JUN 15 '88 10:55 P21
88 06/15 10:56
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2021
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FINDING: 6.0.c
An excessive number (50 to 801) of survey instruments are out of survice,
RESPONSE:
An adequate number of operable, calibrated instruments are
available to support the radiological protection program. The
Authority has recognized a problem in obtaining spara parts for '
certain models of portable survey instruments and has compensated
for this by maintaining a large inventory to ensure an adequate
supply.
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JUN 15 '88 10:55 P22
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'3S 06/15 10:56 2 022
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FINDING: 6.0.d
Portal monitors are neither calibrated nor source chicked. Friskers will not
detect hot particles at observed frisking speeds.
RESPONSE:
The portal monitors referenced in the appraisal have been retired
,
from sauvice and have been replaced wLth high. sensitivity whole
body friskers at egress points from the restricted area. These
,
monitors replace manual whole body frisking techniques and have
adequate sensitivity to detect hot particles. The operation and
calibration of these high-sensitivity whole bod friskers is
controlled by an approved RES Department procedure. y 1
The original portal monitors are being retained at
Security and Secondary Access facilities to detect the incoming
Main
radioactive material and to provide an additional monitoring
capability for personnel exiting the protected area. A procedure
for testing of these monitors will be developed by December 31,
1987.
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JIJN 15 *88 10:56 P24
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Si 06/15 10:57 2 029
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FINDING: 6.0.f
There is a lack of coordinuton of RP responsibilities for equipment purchased
by other groups.
__
RESPONSE:
The equipment cited in the inspecticn report represents an
isolated incident. The control of equipment that is intended for
use in the restricted areas of the plant is provided through the
rcdiation work permit and AIARA review processes in addition to
vigilance maintained by radiation protection personnel located at
the principal access point to the restricteo area and in
psrforming plant radiolo81 cal surveillances. -
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JUN 15 '88 10:57 P25
- 83 06/15 10:58 202o_
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FINDING: 6.0.g
'the review of routine surveys does not detect technical errors.
_
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FINDINCr 6.0.h
liigh alpha activity detected during routine surveys is not investigated. High
volume air samples are not periodically checked for alpha activity.
- .
RESPONSE:
These two items are the result of a single observation. .
The surveys that form the basis for this finding are routina I ,
low-volume air samples. Review activities are prioritized to place
the greatest em?hasis on the most critical areas such as the
oversight of Radiation Work Permits (RWPs) and routine radiation
and contamination surveys. The high alpha result cited in the
Appraisal Report was due to a technical error in the low-volume air
sampling procedure. This resulted in naturally-occurring redon
daughter activity being counted as unidentified alpha. The error
has ' * :- -
re- :ed ?.: '
add h'.::ul 6 ; '. 2 . . . e sa r e po r . ...g vi
anomalous results to radiological supervision has been incorporated
,
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routine survey results hasition, the need for timely review of
into the procedure. In adc l
been emphasized to radiological
- supervision,
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. . . . JUN 15 >88 10:57 P26
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FINDING: 6.0.1
Responsibilities for various facets of the surveillance program is frassented.
1
RESPONSE: '
t
The plant radiological surveillance program
delegated to those grou responsible
is functionally
for
(i.e. psair monitoring is performed the appropriate !
monitoring activity by the
respiratory protection group, radiation and contamination surveys
are performed by the radiation protection group and long-term
trending
ing group.) of dose rates is performed by the radiological engineer-
The Authority does not consider the
functional
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assignment of these duties to be a progranssatic weakness since
routine Supervisor.
General results are under the cognizance of the Health Physics
Long-term dose rate trend analysis is closely
associated with the ALARA program under the cognizance of the
Radiological Engineering General Supervisor.
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