ML20128C697

Insp Rept 50-333/85-12 on 850422-26.Violations Noted:Failure to Adhere to Radiation Protection Procedures & Failure to Control High Radiation Area Keys

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: ML20128C669 ML20128C683 ML20128C697
References
50-333-85-12, NUDOCS 8507030658
Download: ML20128C697 (12)

See also: IR 05000333/1985012

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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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

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Specialist

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K. L. Holsopple, Radittion 5pecialist'

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' Approved by: h m f '/ % 2 6 m 3 'L 4 ////r5

W. J. Pasciak, Ihief, @WR Radiation datd

Protection Section

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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.

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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:

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External Exposure Control

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Internal Exposure Control

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Radioactive and Contaminated Material Control

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Radiological Controls Program Implementation

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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

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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."

• 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

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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

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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-

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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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