IR 05000333/1985006

Insp Rept 50-333/85-06 on 850318-22.Violations Noted:Failure to Adhere to Radiation Work Permit Requirements & Failure to Specify Frequency for Periodic Radiation Surveys for High Radiation Area Control

ML20128B192
Person / Time
Site:	FitzPatrick
Issue date:	05/17/1985
From:	Kramaric M, Mark Miller, Myers L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128B161	List: IR 05000333/1985006 ML20128B157 ML20128B165
References
50-333-85-06, 50-333-85-6, NUDOCS 8505240438
Download: ML20128B192 (8)

Text

.-

,

. ,

,

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-06 Docket N License-N OPR-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: March 18-22, 1985

' Inspectors: 7Md 7. Y M. MTiler, Radiation Specialist S/7/N date

% -M sh/w L. MyerK RadiatYon Specialist date

[, 412$

M.~ Krafnar c, adiation Specialist date f '

Approved by: I /.. b k'V h t $ e7 f N. P(sciaE, Chief, BWR Ra'diation Safety dap Sectj Inspection Summary: Inspection on March 18-22,1985 (Report No. 50-333/85-06)

Areas Inspected: Routine, unannounced safety inspection of the licensee's Radiation Protection Program during outage conditions including: status of previously identified items, selection, qualification and training, Radiation Work Permits, exposure control, and ALARA. -The inspection involved 121 inspector-hours onsite by three region-based inspector Results: Two violations were identified: failure to adhere to Radiation Work Permit requirements (paragraph 5.0) and failure to specify the frequency for performing periodic radiation surveys on the Radiation Work Permits for high radiation area control (Paragraph 6.1).

8505240438 850510 PDR ADOCK 05000333 G PDR

.

.

-

DETAILS

- Licensee Personnel

• H. Glovier, . Resident Manager

• R. Converse, Superintendent of Power

• E. Mulcahey, Radiological and Environmental Services Superintendent

'(RESS).

-T. Bergene, ALARA Supervisor

• D. Dooley, Radiological Engineer D. Dull, Balance of Plant Senior Technician

• C. Gannon, Health Physics General Supervisor J. McCarty, Radiation Protection Supervisor

• A. McKeen, Assistant RESS M. McMahon, Dosimetry Supervisor A.' Stark, Drywell Senior Technician L. Tuell, Drywell Senior Technician J. Wierowski, Radiation Protection Training Supervisor 1.1 USNRC

' Doerflein, Senior Radiation Specialist The inspector also contacted other' licensee and contractor employees during the inspectio .0 Purpose The purpose of the routine safety inspection was to review the licensee's Radiological Controls during the current outage. The following areas were reviewed:

• Status of Previously Identified Items

• Selection, Qualification and Training

• Radiation Work Permits

• Exposure Control

Radiation and High Radiation Area Posting and Control

• ALARA 3.0' Status of Previously Identified Items 3.1- (Closed) Inspector Follow-up Item (50-333/84-06-02): Assignment of training responsibility of contractor health physics technicians to one

-

-department. The inspector determined that the responsibility for qualifying contractor technicians was assigned to the Training Departmen '

.

.

3.2 (Closed) Violation (50-333/84-15-02): Failure to issue Special RWP for the initial drywell entry by an operator. The licensee issued Plant Standing Order-45," Initial Entries and Primary Containment In Effect",

dated September 7, 1984 to require a Radiation Work Permit for initial entry by all non-radiation technician .0 Personnel Selection, Qualification and Training The inspector reviewed personnel selection, qualification, and training against the following criteria:

• Technical Specification 6.3, " Plant Staff Qualifications"

• Technical Specification 6.4, " Retraining and Replacement Training"

• ANSI 18.1-1971, " Selection and Training of Nuclear Power Plant Personnel"

• Licensee Procedure ITP-7C, " Training and Qualification of Contractor Radiation Protection Technicians"

• Radiation Protection Procedures

• Licensee Procedure AP 4.3 " Test and Inspection System"

• Licensee Procedure ITP-3 " General Employee Training" The licensee's performance relative to these criteria for selection, qualification, and training of contractor radiological personnel was determined by:

• Discussion with Health Physics General Supervisor and the Radiation Protection Training Supervisor;

• Review of contractor resumes and training records; and

• Examination of Oral Board Reports for Contractor health physics technicians; and

Review of certificates of Qualification for PASNY technician Within the scope of this review, no violations were identifie .0 Radiation Work Permits The issuance, adherence to and adequacy of the licensee's Radiation Work Permits (RWPs) was reviewed against the following criteria:

.

. .

- -Technical Specification 6.11, " Radiation Protection Program"

• ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"

• Licensee Procedure RPOP-4, Revision 0, " Radiation Work Permit Procedure"

.

Performance relative to these criteria was determined by a review of regular, continuing and special RWPs issued between March 1 and March 21, 1985 and their supporting surveys. In addition, direct observations of work in progress were made by inspecto Within the scope of this review, the following violation was noted:

Technical Specification 6.11 requires, in part, adherence to radiation protection procedures for all plant operations involving radiation exposure and contamination control. Licensee Procedure RPOP-4 requires, in part, compliance with any condition stated on the RWP by all personnel

,

who sign in on the RWP. Procedure RPOP-4 also requires the leadman to be responsible for assuring such compliance. All Radiation Work Permits require that personnel dosimetry (i.e., a thermoluminscent dosimeter (TLD) and direct reading dosimeter) be worn. The Continuing Radiation Work Permit for sorting trash from the radiological controlled area requires, in part, rubber gloves be worn in addition to cloth liner * Contrary to the above, personnel dosimetry was not worn by four individuals who had signed in on an RWP for Drywell Entry, as listed below:

RWP N Date Time In Drywell Estimated Exposure Ext. (1985) 2/25/85 10 minutes 10 mrem 19545-S 3/11/85 55 minutes 10 mrem i 2253-S 3/18/85 5 minutes 150 mrem 2361-S 3/20/85 50 minutes 20 mrem

, The inspector noted that the licensee had identified the personnel entries

'

into high radiation areas without proper dosimetry as required by RPOP-7, Revision 3, " Radiological Incident Investigation." However, the licensee's corrective actions to date were not adequate to prevent recur-rence, e.g., the leadman was not re-instructed regarding this responsi-bilit * Contrary to the above, on March 20, 1985 at about 8:00 a.m., two individuals sorting trash were not wearing rubber gloves with the

, cotton liners as specified on the Continuing RWP for trash sortin L~

.

-O i

__

.

.

'

Failure to adhere to Radiation Work Permit conditions regarding radiation exposure and contamination control on the occasions-noted above consti-

-tutes a violation of Technical Specification 6.11(50-333/85-06-01).

. Within the scope of this review, the following concern requiring licensee attention was also identified:

. * The inspector noted the licensee does not always document if respirators were worn for a particular RWP Entry. The inspector stated this provision should be acknowledged to ensure the required air samples were taken when respirators were being use * Review of the radiation surveys for a number of RWPs indicated that the principal survey was not always liste The licensee stated they would address these concerns. These items will be reviewed during a subsequent inspection (50-333/85-06-02).

6.0 Exposure Control 6.1 Radiation and High Radiation Area Posting and Control

'The' inspector reviewed the adequacy and effectiveness of the-licensee's Radiation and High Radiation Area posting and control. The review was with respect to criteria contained in the followin * 10 CFR 20.203, Caution signs, labels, signals and controls s

• Technical Specification 6.11, " Radiation Protection Program"

• Technical Specification 6.11(A), "High Radiation Area The evaluation of licensee performance in this area was based on;

• independent radiation surveys by the inspector

• observations by the inspector

• discussions with cognizant licensee personnel, and

• review of selected licensee procedure Within the scope of this review, the following violation was identified:

Technical = Specification 6.11(A) requires, in part, that entries into a high radiation area be controlled by issuance of a Radiation Work Permit, and that entries permitted under 6.11(A).1.c be controlled by an individual qualified in radiation protection procedures and that the individual perform periodic radiation surveillance at the frequency specified by the facility in the Radiation Work Permi n

~

g i 7 s .

_ ,

,

n

s-

! Contrary to the above, Special Radiation Work Permits issued for Drywell

Entry for'the period of. March -1-21,~ 1985

failed to specify the_ frequency

-

for: performing periodic radiation surveillances. .The inspect'or noted E that'S-RWPs. issued to control entry into the Drywell, a posted High:

, ' Radiation ' Area, ~only "specify surveys 'at' the ' start of the job' and

-

. ' intermittent 1y'.

Failure to !specify the: frequency for performing periodic radiation surveys on the. facilities Radiation Work Permit was a~ violation of

.

lTechnicalTSpecification 6.11(A)1.c.(50-333/85-06-03).

Within_the scope of this review, the following' concern requiring licensee attention:was also identified:

To prevent unauthorized / inadvertent entry into high radiation areas greater-than 1000 mrem / hour, a guard is-stationed at the access when the-gate'is not locked. Access to this area would be permitted if the

, , .

individual-had a~ blue or orange identification badge and signed an:

. approved RW .

.However, the: inspector noted that a verification of the individual name con the identification badge was not required. The inspector stated that

this step would ensure unauthorized entry into_ high radiation areas did snot occur This item will be reviewed during a subsequent inspection (50-333/85-06-04).

6.2 Personnel Dosimetry and' Exposure Kecords-The inspector reviewed the issuance and use of personnel monitoring devices and the licensee's persor.nel' exposure records program with respect to criteria' contained in the following:

• ~. 10 CFR 20.101, Radiation dose Standards for. individuals in

'

Restricted Areas

10.CFR 20.102, Determination of prior dose

,

• ~ 10 CFR 20.202, Personnel monitoring

-* 10 CFR 20.401,. Records of Surveys, Radiation monitoring, and disposals

'

H '

• Lice _nsee Procedure PDP-1, Revision 1, " Plant Dosimetry Procedures" o

'

a' Licensee Procedure PDP-2, Revision 0, "Use and Control of Direct Reading Dosimeters"

,

--

,.

-

• Licensee Procedure RP0P-7, Revision 3, " Radiological Incident Investigation."

-The licensee's performance in this area was based on review of selected

personnel exposure records, Lost TLD Reports, Lost Direct Reading Dosimeter (DRD) Reports, Unusual Radiological Incident Reports (URIR),

discussions with cognizant-licensee personnel and observations by the

. inspectu Within the scope of this review, no violations were identified except as previously discus' sed in Section 5.0 of this report. The inspector noted that no individual was authorized to receive an exposure greater than Rem without formal review of the individual's exposure histor .3 Internal Exposure Control 1The internal exposure control program was reviewed against the criteria contained in:

• 10 CFR 20.103 " Exposures of Individuals to concentrations of Radioactive Materials-in Air in restricted Areas"

• 10 CFR 20.201 " Surveys"

• 10 CFR 20.401." Records of Surveys, Radiation Monitoring, and Disposal"

• Licensee Procedure RPOP-4, Revision 0, " Radiation Work Permit-Procedure"

• Licensee Procedure RPOP-6, Revision 7, " Respiratory Protection-Procedure"

• Licensee Procedure RPOP-10, Revision 0, " Internal Dosimetry".

The licensee's performance in this area was based on review of the following:

• Radiation Work Permits March 1-21, 1985'

• Nasal Smear Survey Log March 1-20, 1985

• - MPC - hours Tracking Log February 1 - March 27, 1985

• Airborne sampling and analysis

• -

Selection of respiratory protective equipment

• Discussion with cognizant personnel

• Observations by the inspector.

L

,*

Within the scope of this review, no violations were identifie .0 ALARA The inspector reviewed the adequacy and effectiveness of the licensee's ALARA program. The review was with respect to criteria contained in the following:

• Regulatory Guide 8.8, "Information Relevant to Ensuring.that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Reasonably Achievable", Revision 3;

.

• Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As is Reasonably Achievable (Nuclear Power Reactors)", Revision 1-R;

• Regulatory Guide 8.27, " Radiation Protection Training for Personnel at Light-Water-Cooled Nuclear Power Plants", dated April 198 Specific tasks reviewed included: RHR pipe (10 MOV 18) replacement and Drywell insulation removal .

The licensee's efforts in this area were determined through interviews of Radiological Controls personnel and review of applicable documentatio Within the scope of this review, no violations were identifie ' Exit Interview The inspector. met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on March 22, 1985. The inspector summar-ized the purpose, scope and findings of the inspection. A subsequent-phone conversion between Messers. R. Converse and E. Mulcahey of your staff and Mr. W. Pasciak of this office on March 26, 1985 further clari-fled the identified violation discussion in section 6.1 of this repor At no time during this inspection was written material provided to the licensee by the inspector.