05000333/FIN-2011009-02
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Finding | |
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| Title | Failure to implement procedures required by TS 5.4.1 |
| Description | The FitzPatrick Technical Specification Section 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained for the applicable procedures recommended in the Regulatory Guide (RG) 1.33, Appendix A (November 1972 edition). Appendix A, Section G of the RG identifies radiation protection procedures for control of radioactivity for limiting materials released to the environment and limiting personnel exposure. These include access control to radiation areas, contamination control, and personnel monitoring. Section H.2.b of the RG identifies radiation protection and surveillance tests that should be covered by written procedures. These include inspections and calibrations for each surveillance test, inspection, or calibration listed in the technical specifications. 10 CFR 20.1501 (a) states, in part, that each licensee shall make or cause to be made, surveys that may be necessary for the licensee to comply with the regulations in this part; and are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations or quantities of radiation levels, and the potential radiological hazards. A. Entergy procedure RP-OPS-08.01, Revisions 13-16, Routine Surveys and Inspections, Section 6.2, requires that daily surveys and inspections be documented on Attachment 1. Contrary to the above, on mUltiple occasions from 2006 to 2009, RPTs failed to perform daily surveys of the Reactor Building 326 foot elevation airlock. B. FitzPatrick Procedure RP-RESP-03.01, Drywell Continuous Atmospheric Monitoring System, Revisions 18-27, provides instructions for operation and calibration of the General Atomics Electronic Systems Drywell Continuous Atmosphere Monitoring System(s) (DWCAM). It specifies that after valve manipulations, a second individual must verify correct valve position. Attachment 1 documents weekly data and requires initials and signatures for independent verification of valve manipulations performed during these checks. Contrary to the above, on eleven occasions between September 2007 and December 2009, DWCAM valves were manipulated, and an independent verification of the DWCAM valve position was not performed by a second Radiation Protection Technician (RPT). On these occasions, the second verification signature was obtained some undetermined length of time after the surveillance test from an RPT determined to have been on duty the day of the test (but who did not actually perform the independent verification) by the RPT who initially performed the test. C. Entergy procedure EN-RP-104, Personnel Contamination Events, Revisions 14, provides contamination monitoring requirements, and instructions for response to contamination alarms. Specifically, Section 5.6, Documentation of Events requires a condition report, Personnel Contamination Event Log, or Personnel Contamination Event Record, be completed depending on the contamination level. Contrary to the above, on at least one occasion, on an undetermined date prior to June 2009, an RPT did not document a personnel contamination event that exceeded the documentation threshold. Specifically, while the technician took action to address the radiologically controlled area (RCA) exit portal monitor alarm and decontaminate the individuals, the technician did not document a personnel contamination event as required. D. Entergy procedure EN-RP-100, Radworker Expectations, Revisions 0-3, provides basic Radiation Protection (RP) requirements and expectations for radiation workers engaged in radiological work at Entergy nuclear facilities. Section 1.0, Purpose, states that, Adrlerence to these requirements and expectations contributes significantly to the minimization of personnel exposure to radiation and radioactive material and the minimization of personnel contaminations. Section 5.6, Contamination Control, requires that personal items be scanned prior to exiting an RCA. Contrary to the above, on one occasion on an undetermined date prior to June 2009, an RPT removed contaminated personal items from an RCA without having them scanned through the contamination monitor at an RCA exit. |
| Site: | FitzPatrick  |
|---|---|
| Report | IR 05000333/2011009 Section 2RS1 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | TEV: Severity level III |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | W Dean A Defrancisco M Gray D Roberts D Holody K Farrar P Wilson J Lubinski C Miller E Monteith J Teator |
| Violation of: | Pending |
| INPO aspect | |
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Finding - FitzPatrick - IR 05000333/2011009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2011Q4
Self-Identified List (FitzPatrick)
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