IR 05000244/1978025
| ML17244A320 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/13/1978 |
| From: | Crocker H, Jason White, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17244A319 | List: |
| References | |
| 50-244-78-25, NUDOCS 7901190227 | |
| Download: ML17244A320 (22) | |
Text
I Report No. 78-25 U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Docket No. 50-244 License No.
DPR-18 Priority Licensee:
Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York Category Facility Name Rb E. Ginna Nuclear Power Plant Inspection at.
Ontario, New York Inspection conducted:
November 29.through December 1, 1978 Inspectors:
G. P. Yuhas, Rad.a ion Specialist a
e
'gned i
Approved by:
J.
R. White, adi tion Specialist H.
W. Crocker, A ting Cnief, Radiation Support
.Section, FF 5 S Branch da e
i ned date signed ate signed Ins ection Summar
ns ection on ovember 29 throu h December
1978 Re ort No. 50-244 78-25 A~td:R t, dt b
t by dt tb t
b t dtb radiation protection program during operations including: qualifications of personnel; training; radiation protection procedures; posting, labeling, and control; followup on previous inspection findings, and followup on IE Bulletins.
Upon arrival at 6:30 p.m.
November 29, 1978, the control.led areas
.were examined to review implementation of radiation safety and procedures.
The inspection involved 36 inspector-hours onsite by two NRC regional based inspectors.
Results:
Of the six.areas inspected, no items of noncompliance were identified.
on Region I Form 12 (Rev. April 77)
q901190%~/
DETAILS 1.
Persons Contacted
- L. D. White, Vice President, Elect'ric and Steam Production
- L.. S. Lang, Superintendent of Nuclear Production
- B. A. Snow, Station Superintendent
- E. L. DeMerritt, Supervisor, Chemistry and Health Physics
- B.
R-. Quinn, Health Physicist
- D. Filkins, Health Physicist
- R. Watts, Technical Assistant, Health Physics D. Morrill, Training Coordinator
- denotes those present at the exit interview on December 1, 1978.
The inspector also talked with and interviewed several other licensee employees including members of the health physics and training staffs.
2.
Licensee Action on Previous Ins ection Findin s Reference:
I (a)
NRC Documentation Letter, attached Notice of Violation, and Notice of Proposed Imposition of Civil Penalties (50-244/78-.03)
.dated May 1,. 1978.
(b)
Licensee's Response Letter (50-244/78-03)
dated May 23, 1978.
(c)
Inspection and Enforcement Report (50-244/
78-03).
(d)
Inspection and Enforcement Report (50-244/ 78-07)
Reference (b) identified the following actions to be taken by the licensee to strengthen the radiation protection program; the inspector determined the status of each item as listed:
1.
"We have instituted the concept of a foreman for our radi-ation protection group and plan to continue utilizing this measure of supervision."
~Com lated:
This action was implemented during the 'l978 out age as discussed in-reference (d).
The licensee indicated that use of a foreman-during periods of high activity such as refueling outages will be-continue "We have provided the services of a professional to assist in the planning and operation of the health physics area during the outage."
~Com leted:
This action was implemented during the 'l978 out-age as discussed in reference (d).
The same individual will provide assistance during the..1979 outage.
"We have. incorporated the procedure for and have performed the required weekly supervisory inspections of the radiation protection activities, thus providing an audit-approach over-view of those activities."
~Com leted:
A review of records indicate that the weekly inspection of radiation protection activities pursuant to Procedure A-54.6, "Health Physics Tour" have been performed as required since April 1978.
"We immediately implemented and prior to the shutdown a
review of the Ginna Station radiation protection for non-licensed and contractor personnel."
~Com leted:
The licensee has revised those administrative procedures dealing with training, (A-50.9, A-50.9.1, A-50.9.2, and A-50.9.3} and. the "Radiation Control Manual."
A review of records for individuals selected at random indi'cates that non-licensed and contractor personnel'ave, been trai.ned'in radiation protection.
"A qualified consulting organization and the corporate quality assurance group made audits of the radiation protection pro-gram."
~Com leted:
The inspector reviewed an audit of licensee's radiation'rotection program made by an independent qualified consulting organization.
This in depth audit has been reviewed by licensee management, Many of the recommendations presented in the audit report have been implemented by the licensee.
"We will institute a computerized program that will produce timely and required personnel exposure records in acceptable and readily retrievable form which we believe will assure rigorous compliance with the regulatory requirements."
~l'1 ':
TP ll P
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dp g
ly completed, and expects to simplement this system prior to the scheduled February 1979 outage.
This matter will be reviewed in a subsequent inspection.
(50-244/78-25-01)
7.
"We will appoint an experienced radiation safety person as an administrative assistant to the Health Physicist to be respon-sible for the records and other forms, preparing work permits, and other details assigned by the Health Physicist.
The present. clerk or clerks will be responsible to this person."
~Com lated:
An experienced radiation protection technician has been assigned as an administrative assistant to the Health Physicist.
His duties and responsibilities appear consistant with-those described above.
8.
"We will assign a qualified and professional technical'ssistant'o the Health Physicist for special studies, for review of proce-dures,for providing shutdown assistance, and for providing training as required or directed."
,~Com lated:
A qoaTified protessionai technical assistant has been assigned to the Health Physicist.
This individual is on long term assignment from the corporate office.
He is expected to provide-additional. expertise throughout the scheduled February 1979 outage.
(Closed)
Noncompliance (50-244/78'-03-01):
Failure to maintain a
retraining and replacement training program for the facility staff as required by Technical Specification 6.4.
The licensee has revised those administrative procedures pertaining to the training of all facility staff.
The inspector reviewed those procedures, A-50.9, A-50.9.1, and A-50.9.3, to determine compliance with the require-ments of Section 5.5 of ANSI N18.1-1971.,
A review of training records for members of the Health Physics Staff indicates the licensee is performing the training specified in these procedures.
.
(C'losed)
Noncompliance (50-244/78-03-03):
Failure to adhere to procedure A-l.l, "Locked Radiation Areas" as required by Technical Specification 6.11.
The licensee revised A-l.l on November'4, 1978 and has implemented procedure A-54.6, "Health Physics Tour" to insure adherence to the requirements of A-l.l.
The inspector verified by record review that A-54.6 has been performed weekly and the inspector physically checked all areas in the Auxiliary and Intermediate Buildings on November 29, 1978 to verify their locked statu (Closed)
Noncompliance (50-244/78-03-05):
Exposure to individuals to radiation in excess of the limits specified in 10 CFR 20:101.
The licensee revised procedure HP-1'.1, "Issuing Personnel Dosimeters" dated June 30, 1978 to require up-dated exposure history information on those non licensee employees with an incomplete occupational exposure record.
A review of selected records indicates this pro-cedure is being adhered to.
(Closed)
Noncompliance (50-244/78-03-06):
Failure to maintain records of exposure to radiation on Form NRC-5 or equivilant.
Procedure HP-l.l, Revision 5, dated June 30, 1978 requires the use of Form NRC-5.
A review of selected records indicates the licensee is maintaining records showing the radiation exposures for individuals on Form NRC-5.
(Closed) Previously Identified, Item (50-244/78-07-01):
Review lapel air sampler calibration.
The licensee has implemented a
calibration (HP-10.7,
"Flow Calibration of Low Volume Air Samplers" )
- and operation (A-l.2, "Air Sampling Procedure" ) procedure covering use of the Siersat air sampler.
(Closed) Previously Identified Item (50-244/78-07-02):
Evaluate disparities between dosimeter valves.
As previously noted in reference (d),
on numerous instances during 1978, the radiation dose measured by individual's thermoluminescent dosimeters (TLD) was significantly greater than that exposure measured by the individual's other per-sonnel dosimeters (pocket ion chambers and film badge).
The licen-see conducted an evaluation of'hese disparities and reported their findings to the Nuclear Safety Audit and Review Board (NSARB) in a report dated September 27, 1978.
This evaluation concluded that the high TLD results were probably caused by chemically induced luminescence.
Chemically induced luminescence may result from contamination of, the chips with dirt or grease.
The licensee has taken measures to insure better control of TLD chips.
Licensee review of the TLD system will continue, while the film badge will remain the primary dosimeter.
Licensee Res onse to IE Bulletins a.
IE Bulletin No. 78-07, "Protection Afforded by Air-Line Respira-tors and Supplied-Air Hoods"
The licensee responded to the action'equested in this Bulletin in a letter to Region I, dated August 7, 1978.
An in office review indicated that response was incomplete.
The licensee subsequently resubmitted a response to this Bulletin on Sep-tember ll,'978.
The licensee's respiratory protective equip-ment does not include supplied-air respirators operated in the demand mode.
The inspector noted that procedure HP-12.3,
"Selection of Respirators" was revised on September 26, 1978 to incorporate the limitation associated use of supplied air hoods.
b:
IE Bulletin No. 78-08, "Radiation Levels from Fuel Element.
.Transfer Tubes" The-licensee responded to the actions requested in this Bul-letin= in a letter to Region I dated August 11, 1978.
The licensee had evaluated the potential for radiation exposure in areas near the fuel transfer tube and installed several layers of shiel'd block in the access to the: transfer tunnel penetration prior to plant startup..
Subsequent surveys veri-fied the adequacy of this shielding.
In response to the Trojan incident, and prior to issuance of this Bulletin, the, licensee performed a survey of 4he area adjacent to the fuel element transfer tube during fuel movement.
This survey indicated a maximum accessable whole body dose rate of less than 100 mrem/hr.
Upon receipt, the licensee per-formed, the actions requested in this Bulletin.
4.
=-
'ualifications of Personnel The inspector reviewed the qualifications of a recently aequi:red Radiation Protection Technician to determine compliance with the requirements set forth in the American National Standards Institute ANSI N18.1-1971,
"Selection and Training of Nuclear Power Plant Personnel."
The review included, a interview with the individual, which evidenced that the person has at least two years of working experience in area of power reactor health'physics.
No item of noncompliance,.was identified in this are.
~Trainin a.
The inspector reviewed the general employee training provided to individuals pursuant to the requirements of 10 CFR 19.12,
"Instructions to Workers" and procedure A-50.9 "Facility Staff Training Program, Ginna Station Personnel Training Program."
This review consisted of participation in the three hour class, taking the quiz, and a review of records selected at random from those individuals who have been issued. personnel dosimetry.
The inspector also reviewed training records for five female workers to verify that they had been pro-vided. the information presented in the Appendix to Regulatory Guide 8.13, "Instruction Concerning Prenatal Radiation Expo-sure."
6; b.
Procedure A-.50.9.3 "Health Physics Technician Training and Responsibility Limits" in conjunction with procedure A-50.9 were reviewed to.determine compliance with Technical Specifi-cation 6.4 "Training" and Section 5.5 of ANSI N18.1-1971.
Procedure A-50.9, Revision 2, was implemented June
1978, procedure A-50.9.3, Revision 0, was implemented October 12, 1978.
The inspector discussed these training programs with the Training Coordinator, Supervisor, Chemistry and Health Physics, and a Health Physics Technician.
A review of records indicates an active program sufficient to meet procedural and technical specification requirements.
No-items of noncompliance were identified in this area.
Radiation Protection Procedures The inspector reviewed the following procedures against the require-ments set forth'in Technical Specification 6.8, "Procedures,"
Regulatory Guide 1.33; 1972, "guality Assurance Program Require-ments,"
and Technical Specification 6.11, "Radiation Protection Program."
Procedure No.
A-1 A-1. 1 A-1. 2 A-1. 3 A-1. 4 A-1. 5 A-3 Revision No.
Title Radiation Control Manual Locked Radiation Areas Air, Sampling Procedure Smearing Procedure Radiation Survey Procedure ALARA Occupational 'Exposure Containment Access A-50.9 A-50.9.1 A-50.9.3acility Staff Training Program Ginna Station Personnel Training Program Ginna Station Engineers (Cadet, Assistant Station and Station} Training Program Health Physics Technician Training and Responsibility Limits A-54,6 HP-1,1 HP-1.2 HP-1,3 HP-1,5 HP-1,6 HP-3.1 Health Physics Tour Issuing Personnel Dosimeters External Exposure Limits External Exposure Records Dosimeter Discrepancy Evaluation Neutron Exposure Exposure Reports to Individuals and the Nuclear Regulatory Commission
Procedure No.
Revision No.
Title HP-4.1 HP-4.2 HP-4.3 HP-5,1 HP-7'.3 Controlled Area Entry
.
SeTf Reading Dosimeter Use Work Permit Use Area Radiation Surveys Calibration of Alpha Survey Instruments PAC-4S
'HP-7.5.
Pocket. Dosimeter/Accuracy and Leak Test-HP-7.7 Calibration of Beta Survey Instruments
~HP-8.4 HP-9;1 HP-9.2 Radioactive Source Inventory Steam Generator Blowdown Activity Primary to Secondary Leakage Detection and Measurement HP-9.3 HP-10,3 HP-10.7.
HP-11,2 HP>>12,1 HP-12.2 Air Ejector Gas Sampling Flow Rate Calibration of Hi-Volume Air Samplers Flow Calibration of Low Volume Air Samplers Iodine in Air-Charcoal Cartridge Method Usage of Respirators Medical Check, Fitting and Training of Personnel Using Respirators
Procedure No.
HP-12. 3 HP-12.4 HP-12.5 HP-12.6 Revision No.
Title Selection of Respirators Fitting and Testing of Respirators Maintenance of Respirators Issuance, Proper Use, and Return of Respirators Technical Specification 6.11 states:
"Radiation control procedures shall be prepared and made available to all station personnel or other persons who may be subject to radiation exposure at the station.
These procedures shall show permissible radiation, exposure, and shall be consistent with the requirements of 10 CFR Part 20.
The radiation protection program shall be organized and maintained to meet the requirements of 10 CFR Part 20, with exceptions set forth in Section 6.13 of these Technical Specifi-cations.
The program shall be adhered to for all operations involving personnal radiation exposure."
CFR 20.201(b),
"Surveys," requires that such surveys be conducted as may be necessary to comply with the regulations contained in each section of Part 20.
A "survey," as defined in Paragraph 20.201(a),
means
"an evaluation of radiation hazards incident to production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive'materials present."
Procedure HP-1.5, Revision 0, "Dosimeter Discrepancy Evaluation" in section 6.0 "Instructions" states:
"List all personnel whose self-reading pocket dosimeter total for the badge. period exceeds the film badge result by 300 mrem on the Dosimeter Discrepancy Evaluation Form."
The inspector reviewed this criterion for initiation of the'exposure evaluation with the licensee representatives.
The licensee indicated the basis of this criterion included the fact that self-reading pocket dosimeter results're routinely increased 'by a factor of 1.3 for conservatism and individuals frequently read their pocket dosimeters on the high sid The inspector noted that selection of 300 mrem discrepancy as the initiating criterion. for an evaluation is not directly inconsistant with the requirements of 10 CFR 20.201(b),
however, in some circum-stances, failure to evaluate a dosimeter discrepancy of less than this value might result in noncompliance with the requirements of
CFR 20.
No item of noncompliance was identified in this area.
7'.
Postin
, Labelin and Control
'a ~
b.
During tour s of the facility, the inspector verified that the documents specified in 10 CFR 19.11;."Posting of Notices to Workers," were properly displayed.
The inspector toured the controlled areas making independent measurements to determine compliance with the requirements-.
expressed in Technical Specification 6.13 "High Radiation Area;"
CFR 20.203,
"Caution Signs, Labels, Signals, and Controls",".and HP-5.2, "Posting of Radiation Areas and Container,. Label ing. "
No item of noncompliance was identified in.'this area.
8'.
Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at'he conclusion of the inspection on December 1, 1978.
The inspector summarized the scope and findings of the inspection as presented in this report.