u.s. nuclear regulatory commission region i

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U.S. NUCLEAR REGULATORY COMMISSIONREGION I

Report No. 50-333/85-24

Docket No. 50-333

License No. OPR-59 Priority -- Category C

Licensee: New York Power Authority

P. O. Box 41

Lycoming, New York

Facility Name: James A. FitzPatrick Nuclear Power Plant

Inspection At: Scriba, New York

Inspection Conducted: August 19-23, 1985

Inspectors: h$td[N///dA., f .3!/IM. M111er, Radiltlon Specialist Idatd

) $ 1%. Abt Vh$W. (p ,Rpiatif1 Specialist ' dat

Approved by: ' (C Cf N j j(tb(N.' Pas 6iik, Chief,BWRRadiological d eProtection Section

Inspection Summary: Inspection on August 19-23,1985 (Report No. 50-333/85-24)

Areas Inspected: Routine, unannounced safety inspection of the licensee's Ra-dioactive Waste Management Program and improvements to the Post Accident Sam-pling System including: licensee action on previously identified items, man-agement control, training, liquid waste processing, solid waste processing andpackaging, quality assurance, surveillances, and low level radioactive wastestorage. The inspection involved 76 inspector-hours onsite by two region-basedinspectors.

Results: No violations were identified.

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DETAILS

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i 1.0 Licensee PersonnelI *R. Converse, Resident Manageri *W. Fernandez. Superintendent of Power

*D. Lindsey, Operations Superintendent4

*E. Mulcahey, Radiological and EnvironmentalServices Soperintendent (RESS)

*R. Patch, Quality Assurance Superintendent*R. Locey, Assistant Operations Superintendent and'

Acting Waste Management General Supervisor; *A. McKeen, Assistant RESSi T. Bergene, ALARA Supervisor

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,*B. Gorman, Chemistry General SupervisorL. Johnson,.QA Supervisor'

E. Isern, Site-EngineerS. Masciulli, Supervisory Radiat!nn Engineer (Corp.)D. Robert, Radiological Waste SupervisorR. Sarkissian, Assistant Shift SupervisorK. Szeluga, Radiation Protection Supervisor

' J. Wierowski, Radiation Protection Training SupervisorA. Young, Decontamination and Shipping SupervisorD. Grodi, Assistant QA EngineerJ. Austin, Nuclear Operator Grade CC. Camerchioli, Nuclear Operator Grade CK. Wells, RES Senior Technician.

! The inspector also contacted other licensee and contractor employees* during the inspection.I * Denotes attendance at exit interview,

i 2.0 The purpose of the routine safety inspection was to review the licensee'sRadioactive Waste Management Program and status of Post Accident Sampling

! System ~ follow-up items. The following areas were reviewed:,

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Status of Previously Identified Itemsj *

Radioactive Waste Management Control*

Training*

; Liquid Waste Processing*

! Solid Waste Processing and Packaging*

| Quality Assurance*

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* - Radioactive Waste Surveillances

Low Level Radioactive Waste Storage Facility*

3.0 Status of Previously Identified Items

3.1 (Closed) Inspector Follow-up Item (333/80-20-22):

Expedite repair of augmented Off-Gas Treatment System to permitoperation. The inspector noted that the recombiner and charcoalfilters for the Off-Gas System were operational after the 1985refueling outage as committed to NRC by licensee management. Mod-ifications and repairs to the system to ensure operability includedrefrigeration units to improve dew points and new hydrogen monitors.

3.2 (Closed) Inspector Follow-up Item (333/84-09-02): ,

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Provide method for shipment tracking when burial site receipt is notreceived. The inspector reviewed procedure F-0P-48A, " Documentationof Radwaste Shipments", Revision 7 dated July 10, 1985. Proceduralsteps had been addressed to track shipments, investigate and reportto the NRC, if verification of receipt of shipment was not receivedfrom the burial site within twenty days of transfer from theFitzPatrick site.

-3.3 (Closed) Inspector Follow-up Item (333/84-09-03):

Improve training of RES Technicians in Transportation Area. Theinspector reviewed a four day training program entitled, " RadioactiveMaterial Packaging, Transportation and Disposal" which addressed therequirements of.IE Bulletin 79-19. The training program for REStechnicians was verified by the inspector to have been completed onJanuary 28, 1985. A two year training cycle has been specified. The

| inspector noted lab exercises using the Radman computer program was a :'

part of the training curriculum.


Revise the PASS procedure to assure that no dilution water is heldt

up in the line. The inspector noted procedure PSP-17 was revised toaddress injecting air into the dilution line to prevent water hold- '

up.

3.5 (C'osed) Inspector Follow-up Item (333/84-24-02):!

Revise the PASS procedure so that personnel are aware of the properloading and installation of iodine / particulate filter assembly.

|' The inspector noted that instructions were =dded to PSP-17 delinea-

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ting proper loading and installation of the iodine / particulatefilter assembly. In addition, the inspector observed this assemblywas color coded to aid technician handling.

3.6 (Closed) In'spector Follow-up Item (333/84-24-10):

Address sample purging and-in plant field analysis in applicableprocedures. Sample purging to remove trapped noble gases fromiodine cartridges was included in the applicable procedures.


Calibration. stickers to instruments on PASS panel were incorrectlyfilled in. The inspector observed that new calibration stickers had

been attached to the instruments which included the " calibration duedate".

3.8 (Closed) Unresolved Item (333/85-18-03):

Ball valve in PASS panel observed leaking during 1985 annual exer-cise. The inspector discussed with the General Chemistry Supervisor.

the actions taken by the RES technicians during the observed exer-cise. In addition, the licensee stated that the water observedleaking was water from the dilution flask that escaped through a ball

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valve . The licensee stated that there have been no reoccurrencesof this problem. However, a new ball valve has been ordered and willbe replaced.

The following inspector follow-up items remain open pending furthercorrective action in accordance with licensee commitments.

3.9 (0 pen) Inspector Follow-up Item (333/84-24-06):

Establish preventative ~ maintenance program for PASS. The licenseehad drafted a formal preventative maintenance program for those PASScomponents recommended by the vendor. This action should be c.om-pleted by December 31, 1985. With regard to coordinating calibra-tions between the RES and I&C departments, this action should be com-pleted by November 30, 1985. The inspector noted that the PASS ra-diation monitor alarm setpoints were lowered to the level specifiedin the PASS Operating Procedure (PSP-17). This procedure was re-vised also to address installation 'of silver zeolite cannistersduring use of the PASS.

3.10 (0 pen) InspectorFollow-upItem(333/84-24-08)

Improve particulate iodine sampling capabilities. The inspectornoted emergency procedure EAP-21, Revision 7, " Meteorological DataAcquisition System" was revised to address incorporation of iodine

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results into the source term assessment process. -The licensee'sother planned actions to improve particulate / iodine sampling werescheduled to be completed by December 31, 1985.

3.11 (0 pen) Inspector' Follow-up Item (333/84-24-09):

Improve high range containment monitoring. The inspector reviewedan engineering evaluation that recommended one of the two contain-ment detectors he relocated to decrease direct dose rate effectsfrom adjacent plant equipment. The licensee expects to complete .

this action during the 1986 refueling outage. The inspector alsonoted that procedure RTP-34, " Containment Radiation Monitoring-PostAccident".will be revised by October 31, 1985 to include specificresponse curves for estimating percent of core damage.

3.12 (0 pen) Inspector Follow-up Item (333/84-24-11):

Improve calibration for PASS monitors. The licensee has made plansto procure a calibration source that would provide a three pointradiation dose rate input for the four decade PASS monitors. Thelicensee expects to complete this action by November 30, 1985.

4.0 Management Control

The. responsibility for the administration, technical direction and properprocessing and shipment of radioactive waste is the function of the WasteManagement General Supervisor.

The licensee had documented the management control for radioactive wasteprocessing in Administrative Procedure No. 1, Revision 11 " OperatingStaff Responsibilities and Authorities." The inspector discussed withthe Waste Management General Supervisor, who was promoted recently toAssistant Operations Superintendent, the responsibilities and authoritiesdesignated in the Operations Department Organization chart, and as ad-dressed in the Radwaste Supervisory position descriptions. The inspectornoted that a replacement for the WMGS had not been selected. The inspec-tor also discussed the recent change (July 1985) to a new vendor foroperations and monitoring of the solidification process. A copy of thevendor's topical report was available and the vendor procedures were re-viewed by the Quality Assurance Department. (For details, see Section 8.0of this report).

The inspector reviewed selected program procedures and toured theRadwaste Control Room, Reactor and Turbine Buildings, dry active wastestorage and compactor work area, and Mobile solidification area. Inaddition, radwaste operators and the Radiological Waste Supervisor wereinterviewed to determine their knowledge of the liquid and solid radwastesystems and processin~g procedures.

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1 The inspector also discussed with the WMGS and the Decontamination andShipping Supervisor, the following management programs: Water Inventory-

Balance, Volume Reduction and Material Control, and Reclamation of Con-taminated Areas. These programs were receiving adequate management,

attention. The licensee also stated that there were no Licensee EventReports (LERs) associated with the Radwaste Systems for the past two

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Within the scope of this review, no violations were identified.;

5.0 Training

. Personnel training in radwaste processing and handling activities was! reviewed against the criteria contained in IE Bulletin 79-19, " Pack-| aging of Low Level Radioactive Waste for Transport and Burial."

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The licensee's performance relative to this criteria was determined by Idiscussions with the Decontamination and Shipping Supervisor, RESTraining Supervisor and radwaste operators, and by review of training;

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documentation.'

Within the scope''df this review no violations were identified.!

6.0 Liquid Radioactive Waste Processing* 6.1 Liquid Radioactive Waste Systems

| The licensee's liquid radioactive waste system was reviewed withrespect to Technical Specification 6.8 " Procedures," for thecollection, transfer, concentration and limiting of liquid waste,and ANSI N197-1976, "BWR Liquid Radioactive Waste ProcessingSystem," for proper operation and adequate maintenance of the system.

The licensee's performance in this area was determined by discus-sions with the Radioactive Waste Operations Supervisor, plant toursincluding the R/W Control Room, selected waste tank and pumpcubicles, and review of operator shif t logs and procedure F-0P-49,Revision 16, " Liquid Radioactive Watte."

Within the scope of this review, no violations were identified. How-ever, the inspector noted that the liquid discharge goal for 1985,which was 2,000,000 gallons, would be exceeded slightly. Thelicensee indicated this was because of many leaks in the turbinebuilding closed loop heat exchangers. The inspector was informedthat these heat exchangers were being replaced.

6.2 Liquid Effluent Releases'

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The inspector reviewed the following procedure and records forliquid radioactive waste discharges to determine if the licensee was

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in compliance with the requirements of Environmental Technical Speci-fication 2.3, " Radioactive Discharge":

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Procedure ~No. F-0P-49, Revision 17, " Liquid Radioactive Waste*,

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Procedure No. PSP-4, " Waste Water Sampling and Analysis"*

Liquid Radioactive Waste Discharge Permits for 1985*

! Additionally, the inspector interviewed selected radwaste andchemistry personnel.

The inspector determined that the licensee was in compliance with,

| its Environmental Technical Specifications and implementing i

procedure.I

6.3 Unmonitored Release Paths

| The inspector reviewed the licensee's surveillance program that ad- '

| dresses the concerns of I.E. Bulletin 80-10. Documents included in| this review were Procedure No: PSP-9, " Miscellaneous Plant Systems| Sampling and Analysis", and associated surveillance records for 1985.

f Additionally, the inspector interviewed selected chemistry personnel.

No items of noncompliance were identified.

i 6.4 Radwaste Modifications

The inspector reviewed a list of modifications requested for theRadwaste System. The list included modifications that were re-

'quested back to 1976. The inspector noted that the intent of themajority of the modifications was to reduce occupational radiation i

exposure. L

Through discussions with licensee's ALARA staff, both at the J. A.FitzPatrick site and at the White Plains Office, it was determined ,

that no formal ALARA review was performed for these modifications.However, the licensee was currently developing a program that wouldfacilitate detailed ALARA reviews for requested plant modifications.

|The inspector stated to the licensee that the implementation of thisprogram is encouraged and will be reviewed in a future inspection(50-219/85-24-01).

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7.0 Solid Waste Processing and Packaging

The licensee's solid radioactive waste program was reviewed with respectto Technical Specification 6.8, " Procedures," for the control, handling, !

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packaging and limiting of solid radioactive waste, and 10 CFR 50.59," Changes, tests and experiments," for changes to the solid radioactivewaste systems.. The licensee's program for waste solidification and com-pliance to 10 CFR 61.55 and 10 CFR 61.56 was reviewed, 'owever the Tech-nical Specification for the Process Control Program was awaiting approval.

The licensee's performance in this area was determined by discussionswith Radioactive Waste operations and shipping personnel and RES staff;plant tours including the Dry Active Waste (DAW) sorting and compactorarea and mobile waste solidification area; review of safety evaluationsfor Radioactive Waste Systems; and review of selected program proceduresincluding:

F-OP-48, Revision 8, " Solid Radwaste System," dated August 4, 1982*

F-0P-488, Revisicn 10, " Waste Packaging and Handling", dated*

August 29, 1984

F-0P-48C-9, Revision 0, " Handling Procedure for the NUS 14-170 Cask"*

F-0P-48E, Revision 0, " Radioactive Material Segregation," dated*

November 16, 1983

SS.001, Revision G.1, " Process Control Program for Radwaste Solidifi-*

cation"

WACP-10.1.6, Revision 6, " Control of Modifications, Component*

Changes, and Safety and Environmental Impact Reports," datedJuly 7, 1982

PSP-8, Revision 11, " Radioactive Material Shipping Procedure," dated*

August 13, 1984

With the scope of this review, no violations were identified. However,the following concerns were identified.

Procedures and flow diagrams (operator aids) for the processin~g of*

radwaste were being updated to describe the actual transfer opera-tions. For example the former methods for transfer of solid waste tothe centrifuge and transfer of spent resin via the spent resin pumpswere detailed, along with the modified and currently implementedmethods for transfer of solid waste to the mobile solidificationsystem and transfer of spent resin via the waste concentrator pump.

This project was initiated January, 1984 and the completion of therevision of all the radwaste procedures is expected to be completedby December, 1985. The inspector noted that this project should becompleted, as scheduled, given the numerous changes to the RadwasteSystems. This item will be reviewed during a subsequent inspection(333/85-24-02).

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With regard to radwaste system changes, the inspector requested the*

safety evaluation report for the use' of the mobile solidificationsystem that had been used instead of the centrifuge since 1982. Theinspector also noted that a new vendor had replaced the originalvendor solidification system in July,1985. The licensee indicatedthey were unable to locate the safety evaluation and believed thatone may not have been performed.

The inspector discussed at the exit interview IE Circular No. 80-18,10 CFR 50.59 Safety Evaluations for Changes to Radioactive WasteTreatment Systems to which the licensee stated they would review forapplicability. Given the recent change to a new vendor solidifica-tion system, this recent change need only to be addressed.

This item is considered unresolved and pending review of the,

licensee'saction(333/85-24-03).

8.0 Quality Assurance -

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The implementation of the licensee's Quality Assurance Program (QAP), asapplied to the "Radman" classification / characterization program, was re-viewed against the cri'teria contained in 10 CFR 50, Appendix B and 10 CFR20.311(d)(3).

The licensee's performance relative to this criteria was determined from| discussions with the QA Supervisor, Associate QA Engineer, and the RES' Supervisor; and from review of QA procedure reviews and monitoring reports

for 1985 with regard to radioactive waste solidification and classifi-cation, and review of an independent appraisal (JAF:84-01) dated July,

; 1984. '

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Nithin the scope of this review, no violations were identified, however 1

the following concern was identified: [,

Based on a review of 1984 and 1985 audit reports, additional QA*..

surveillances should be made of the Radman computer program to ensure :; compliance with 20.311 (d)(3). The licensee stated increase sur-! veillances had been planned for review of the PCP by performing a

value line-up audit and that the Radman program will also be includ-ing as part of the surveillances. This item will be reviewed duringa subsequent inspection (333/85-24-04). !

'I9.0 Radioactive Waste.Surveillances !

9.1 In-Place Filter Tests f

The inspector reviewed the reports for the 1985 in place filter Ia

tests for the following filter trains with respect to Technical ;

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Specifications 4.7(B) and 4.11(A), and ANSI /ASME N510-1980, " Testingof Nuclear Air Cleaning Systems:

SGTS filter train*

Control Room filter train*

Technical Support Center filter train*

Within the scope of this review, no violations were identified.

9.2 Effluent Monitor Calibration

The inspector reviewed the 1985 calibration records for thefollowing effluent monitors with respect to the Environmental Tech-nical Specification 2.3, " Radioactive Discharge" requirements andANSI N13.10-1974, " Specification and performance of on-site instru-mentation for continuously monitoring radioactivity in effluents":.

| Liquid waste discharge monitor*

Stack monitor*

Vent monitors*

Within the scope of this review, no violations were identified.

10.0 Low-Level Radioactive Waste Storage Facility

The licensee has started construction of a Low-Level Radioactive StorageFacility at the James A. FitzPatrick site. Projected completion isDecember, 1985. The licensee stated that the facility would provide 113years storage for liners, 2 years storage for LSA waste and a trench for~ 60 high level waste drums. The plans for a second on-site storagebuilding (a mirror image of the present building) are available, if addi-tional storage capabilities would be necessary af ter January 1986.

'11.0 Exit Interview

The inspector met with licensee representatives (denoted in Section 1) atthe conclusion of the inspection on August 23, 1985. The inspectorsummarized the purpose, scope and findings of the inspection. At no timeduring this inspection was written material provided to the licensee bythe inspectors.

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