IR 05000244/1980006
| ML17250A638 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/14/1980 |
| From: | Knapp P, Serabin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17250A634 | List: |
| References | |
| 50-244-80-06, 50-244-80-6, NUDOCS 8009240205 | |
| Download: ML17250A638 (26) | |
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N Docket No.
50-244 U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I License No.
DPR-18 Priority Category Licensee:
Rochester Gas and Electric Com an 89 Ea'st Avenue Rochester, New York 14649 Facility Name:
R.
E. Ginna Nuclear Power Plant Inspection at:
Ontario, New York Inspection conducted:
April 29-May 2, 1980 Inspector:
-
C7 J.
A. Serabian, Radiation Specialist
-//- 5'0 date signed date signed Approved by:
P.
.
Knapp, Chic
, Radsatio upport Section, FFMS Branch date. signed date signed Ins ection Summar
Ins ection on A ril 29-Ma 2.
1980 Re ort No. 50-244 80-06)
reas Ins ecte
Routine, unannounced inspection by a regional based inspector during refue ing operations including:
advanced planning and preparation; training; exposure control; fespiratory protection; posting and control; surveys; and. plant tours.
Also, licensee actions on previous inspection findings were reviewed.
Upon arrival at 7:05 a.m.,
and at other times during the inspection, areas where work was being conducted were examined to review radiological procedures and practices.
The inspection involved 32 inspector-hours onsite by one NRC regional based inspector.
Results:
Of. the seven areas inspected, no items of noncompliance were found in six areas, one item of noncompliance was identified in one area (Infraction - failure to follow radiation protection procedures in accordance with Technical Specification 6.11} (Paragraph 11).
One deviation from generally acceptable practice in industry was identified in one area (intentionally handling contaminated or potentially con-taminated material without protective gloves)
(Paragraph 11).
Region I Form 12 80D924~
DETAILS Persons Contacted
- Mr. B.
- Mr. J.
- Nr.,L.
- Mr. D.
- Nr. E.
- Mr. W.
Mr. N.
.
Mr. D, Nr. L.
- Mr. J.
Mr. J, Nr, E.
Nr. C.
Snow, Station Superintendent Noon, Assistant Station Superintendent Lang, Superintendent of Nuclear Production Filkins, Supervisor of 'Health Physics and Chemistry DeMerritt, Technical Assistant Goodman, Health Physics Foreman Pyle, Numanco Health Physics Supervisor Morrill, Training Coordinator Smith, Shift Supervisor Bodine, guality Control Inspection Engineer Snyder, guality Assurance Specialist Beatty, Technical Project Coordinator Mitrano, Job Foreman
- denotes those present at the exit interview.
The inspector also interviewed other licensee employees including members of the health physics staff (station and contractor),
reactor operators, and maintenance personnel.
Licensee Action on Previous Ins ection Findin s (Closed)
Noncompliance (50-244/79-01-03):
Failure to evaluate whole body count results.
Through review of documentation and discussions with licensee representatives, the inspector verified that a detailed dose evaluation, of the individual in question, had been performed by a licensee consultant, and indicated that no regulatory exposure limits had been exceeded.
Through review of procedures,. the inspector. verified that an existing procedure HP-2.2, Revision 7,
"Whole Body Count Operation",
has been revised, and a new procedure, Procedure No. HP-2.5, Revision 2,
"Whole Body Count Evaluation",
has been developed.
to ensure that adequate evaluations are performed and fully documented in the future.
(Closed)
Noncompliance (50-244/79-18-07,):
Failure 'to have copies of docu-ments referenced by the Certificate of Compliance.
The inspector verified through review of records that'he documents referenced, which were not available during Inspection No. 79-19 were now on file.
The inspector reviewed maintenance Procedure.
No. M-.18.6, Revision 2, "Handling, Loading, and Unloading of CNSI Transport Cask CNS-8-120, Model Number LL-50-100",
and Procedure No. (CIP-.21, Revision 3, "Shipping Package CNS-8-120 Inspection",
and verified that steps have been included to check for the references cited by the Certificate of Complianc (Closed)
Noncompliance (50-244/79-18-08):
Failure to identify the presence of Sr-90 on radioactive materials shipment papers.
Through review of Pro-cedure No. RD-10, Revision 7, "Shipping Radioactive Material", the inspector verified that the procedure has been revised to require that isotopic con-tents be listed on radioactive materials shipment papers.
(Closed)
Noncompliance (50-244/79-18-02):
Failure to load and close radioactive materials, packaged, for transport,.in accordance with written and approved procedures.
Through review of Procedure No. M-18.6, Revision 2, "Handling, Loading, and Unloading of CNSI" Transport Cask CNS-8-120, Model Number LL-50-100",
and Procedure No. gCIP-21, Revision 3, "Shipping Package CNS-8-120 Inspection",
the inspector verified that steps have been included detailing closing and loading instructions for packages of radioactive materials for transport.
(Closed)
Noncompliance (50-244/79-18-05):
Failure to respond to audit findings. Through review of, licensee memoranda, the inspector verified that a response to AFSAR-1 on audit 79-33:CA was submitted to the guality Assurance group on December 17, 1979.
(Closed)
Inspector Followup Item (50-244/78-07-01):
Lack of a procedure for use of lapel air samplers.
The inspector verified through review of Procedure No. HP-11. 10, Revision 2, "Air Sampling When Siersat Low Volume Air Samples" (sic), that a procedure governing lapel air sampler use has been developed.
(Closed)
Inspector Followup Item (50-244/79-18-06):
Inconsistencies found in (1979) Semi-Annual Effluent Release Report.
During Inspection No. 79-18, the inspector identified an inconsistency in which the tabulation of total solid waste activity and total solid waste shipped is inconsistent with the sum of the individual values listed.
The licensee submitted a
letter to B, H. Grier,, Director, Region I, dated May 18, 1980, which reported the correct (and consistent), values.
The inspector verified these values through in-office comparison of them with those listed in the Semi-Annual Effluent Release Report (March 1979 through December 1979).
(Closed)
Inspector Followup Item (50-244/79-18-01):
Confusion and incon-sistencies in radwaste procedures.
Review of Procedure Nos.
RD-9, Revision 4, "Preparing Waste for Shipment and Storage",
and RD-10, Revision 7,
"Shipping Radioactive Material", during Inspection No. 79-18, indicated that a revision was needed in order to avoid confusion and inconsistencies in these procedures.
The licensee has subsequently superseded Procedure Nos.
RD-9 and RD-10 with five procedures which more clearly delineate requirements governing burial site criteria and radioactive materials shipping paper (Closed)
Management Control Systems (50-244/79-18):
Due to the number of items of noncompliance, in the area of radioactive waste shipments, identi-fied during Inspection No. 79-18, the licensee indicated that the respon-sibility for management of radioactive waste shipments would be specifically assigned to one individual.-. The inspector verified through discussion with licensee representatives that thi.s individual assignment has been made.
3.
Procedures The inspector'reviewed the following radi'ation protection. procedures, those related to the refueling outage, in particular, against the requirements set forth in Technical Specification 6.8, "Procedures",
Regulatory Guide 1.33,. 1972, "guality Assurance Program Requirements,"
and Technical Specifi-cation. 6. 11, "Radiation Protection Procedures".
HP-1.2, "External Exposure Limits", Revision
HP-1.3, External Exposure Records",
Revision
HP-2. 1,
"Whole Body Count", Revision
HP-2.2,
"Whole Body Count Operation",
Revision
HP-2.5,
"Whole Body Count Evaluation", Revision
HP-3.2, "In-Plant Reporting of Current Exposures",
Revision
HP-5. 1, "Area Radiation Surveys",
Revision
HP-5.2, "Posting of Radiation Areas and Container Labeling", Revision
HP-6.1,
"Contamination Limits", Revision
HP-6. 2, HP-6.3,
"Posting of Contaminated and Airborne Areas", Revision
"Personnel Decontamination",
Revision
HP-11.4,
"High Volume Air Sampling", Revision
HP-11.7,
"Drager Multi Gas Detector Use", Revision
HP-11,8,
"Condensed Hydrocarbon Content of Breathing Air", Revision
HP-11.10, "Air Sampling When Siersat Low Volume Air Samples",
Revision
HP-12.1,
"Usage of Respirators",
Revision
HP-12.2,
"Medical Check., Fitting and Training of Personnel Using Respirators",
Revision
HP-12.3,
"Selection of Respirators",
Revision
HP-12.4, "Fitting and Testing of Respirators",
Revision
HP-12.6,
"Issuance, Proper. Use and Return of Respirators",
Revision
HP-12.7,
"Constant Flow Breathing Air System Setup, Revision
A-52.1.4, "Health Physics and Chemistry Shift Changeover, Revision
A-102.10,
"Health Physics Technician Training and Responsibility Limits", Revision
The inspector noted that Procedure HP-5.2, indicates that if the radiation dose rate at 18 inches from a (point) source exceeds 100 mrem/hour, the area must be posted as a High Radiation Area.
The inspector informed a
licensee representative that the regulatory requirements define a High Radiation Area as an area accessible to personnel. in which radiation existed at such levels that a major portion of the body could receive a dose in excess of 100 mrem in any one hour.
The inspector reviewed Procedure HP-5.1 and noted that the aforementioned requirements are included in this procedure.
The inspector also reviewed High Radiation Areas during facility tours and identified no areas which were not in accordance with the regulatory requirements.
During in-office review of previous inspecton findings, the inspector noted that this matter had been previously identified during Inspection Ho. 78-07.
In addition, the inspector also reviewed several, seven, maintenance pro-cedures associated with steam generator work to determine whether health physics precautionary notes had been incorporated.
The inspector found that all of the seven procedures reviewed include such precautionary notes.
These included provisions to ensure Special Work Permit (SWP) issuance, health physics coverage, dose rate measurements, containing liquids, and use of air monitors.
Six of the seven procedures made use of check-off sheets, No items of noncompliance were identified in this are.
Advanced Plannin and Pre aration a ~
Increased Health Ph sics Staff To augment.its staff for the refueling outage,.the licensee contracted for the services of an outside health physics firm.. Approximately 16 additional'health physics technicans were assigned.
The inspector noted that pursuant to Technical Specification 6.4,, "Training", (which endorses ANSI N18. 1-1971)
those technicians -in responsible positions must have two years of experience in health physics.
The inspector reviewed 14 resumes and made observations of work assignments in the field.
No instances were identified in which an individual was assigned to a responsible position without having the requisite experience.
The licensee's implementing procedures governing health physics technician training and responsibilities are found in Procedure A-102.10, "Health Physics Technician Training and Responsibility Limits", Revision 1.
S ecial Trainin The most radiolo'gically significant job during the refueling outage involved steam generator entries (incident to eddy current testing and tube plugging operations),
The licensee has implemented a special training program, pursuant to
CFR 19.12, "Instructions to Workers".
The program includes health physics, use of air supplied (respirator)
hoods, and dry runs using steam generator mock-ups.
A licensee repre-sentative stated all steam generator evolutions were practiced using the mock-up and that during such practices, personnel wore protective clothing and the air supplied hoods to simulate actual working con-di'tions
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The inspector interviewed workers and reviewed the training records for five individuals who had made steam generator entries, and verified that the special training had been conducted.
Ex osure and Contamination Control During tours of the controlled area in the Reactor Containment, the inspector observed that the licensee had coranenced a modification for permanent shielding of the fuel element transfer tube.
A licensee representative stated that this modification was expected to be com-pleted prior to the end of the outag Regarding contamination control, a licensee representative stated that portable containments for controlling the spread of airborne and surface radioactive material had been used (e.g., erecting tents at the steam generator platforms).
No items of noncompliance were identified in this area.
5.
Traininq The inspector reviewed the training records of 11 individuals, who had been involved with steam generator and reactor head, work, to determine if the training required by 10 CFR 19.12, "Instructions to Workers",
had been con-ducted.
This training is implemented via Procedures A-102.2,
"R.
E. Ginna Administrative Controls Training Program",
Revision 2, and A-102.3,
"R.
E.
Ginna Health Physics Orientation Program",
Revision 0.
The inspector veri-fied that the individuals had received the required training.
No items of noncompliance were identified in this area.
6.
Ex osure Control The inspector reviewed the licensee's personnel monitoring program against the following requirements.
CFR 20. 101, "Radiation Dose Standards for Individuals in Restricted Areas"
CFR 20. 102, "Determination of Prior Dose" 10 CFR 20. 103,
"Exposure of Individuals to Concentrations of Radio-active Materials in Air in Restricted Areas"
CFR 20. 104,
"Exposure to Minors" Technical Specification 6. 13, "High Radiation Areas" The inspector selected exposure records of 20 individuals whose quarterly external whole body exposure was in excess of 1> Rem (but less than 3 Rem)
during the first calendar quarter (1980).
The inspector verified that the Form NRC-4's had been completed prior to exceeding l>4 Rem.
The inspector also reviewed records of internal exposure assessments.
Whole body count data for 37 individuals, covering the period from January 1 through March 31, 1980, indicated internal depositions that were much less than the limits specified in 10 CFR 20. 103(a)(1).
(All values reviewed were less than one percent of the Maximum Permissible Body Burden.)
The inspector reviewed the licensee s Weekly MPC-hour (Maximum Permissible Concentration)
Log for the period covering from December 30, 1979, through April 26, 1980.
The inspector noted that. the log indicated that there were no instances, during the period of'eview, in which the 40-hour control measure specified in 10 CfR 20. 103 had been exceeded.
The highest individual value during that period was 4.22 MPC-hours.
The inspector reviewed the High Radiation Area ("R") Key Log, which is maintained pursuant to Technical Specification 6. 13.
The inspector noted that all of the'(18)
High Radiation Area keys were accounted for.
No items of noncompliance were identified in this area.
7.
Res irator Protection Pro ram The inspector reviewed the licensee's respiratory protection program (which included procedure review, interviews of personnel, inspection of the respirator maintenance and cleaning facility, and review of air quality test results)
against administrative, procedural, and technical require-ments in the following:
CFR 20. 103,
"Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas",, Section (c); and Regulatory Guide (R.G.,) 8. 15; "Acceptable Programs for Respiratory Protection", October, 1976.
The inspector's review entailed verification of the following.
Section R.G. 8.15 Re uirement c.4.a.
Air sampling program sufficient to evaluate the hazard.
c.4.b.
c.4.c.
c.4.d.
c.4.f.
c.4.h.
Written procedures to ensure proper training of personnel using respiratory protection equipment.
Written procedures to ensure adequate fitting of respirators.
Written procedures for maintenance of respiratory protective equipment.
Bioassays to evaluate individual exposures.
Medical determination of individual 's physical ability to wear respiratory protective equipmen Section (R.G. 8.15)
c.5.
c.8.a.
c.8.c.
Reauirement Use of certified respiratory protective equipment as per
CFR Part 11.
Respirable air of approved quality provided.
No credit taken -for use of sorbents against radioactive materials.
c.8.d.
c.8.i.
High efficiency.filter media in air-purifying respirators.
Facelets not to be used.
No items of noncompliance were identified in this area.
8.
~Postin The inspector toured the facility on April 29, 1980, and at subsequent times during the inspection.
Posting and radiation area control were reviewed against requirements in Technical Specification 6. 13, "High Radiation Area", and
CFR 20.203,
"Caution Signs, Signals and Controls".
During the tours of the controlled areas, the inspector observed that radioactive material storage appeared satisfactory in relation to control requirements and that radioactive materials containers appeared to be adequately identified and labeled in accordance with 10 CFR 20.203(f).
The inspector further observed that Radiation and High Radiation Areas appeared to be posted and controlled as required.
The inspector performed independent radiation dose rate measurements, at random, to verify that the areas were posted as required.
No items of noncompliance were identified in this area.
9.
~Surve s
The inspector reviewed the licensee's survey program. against the require-ments of '10 CFR 20.201(b).
Surveys made to support several active Special Work'Permits (SWP) were reviewed, as follow SMP Number Tie1e 694 695 1572 1573 Remove Inserts on "B" S/G Cold and Hot Legs and "A" S/G Cold and Hot Legs Initial Radiological Survey "B" S/G and
"A" S/G Hot and Cold Legs and Tent Survey Install Nozzle Covers
"A" S/G Hot and Cold Legs Head Lift and Initial Survey UT Reactor Vessal Flange at 24 The inspector determined that physical. radiation surveys had been made of whole body, skin of the whole body, and extremity exposures so as to determine compliance with the requirements of 10 CFR 20. 101.
No items of noncompliance were identified in this area.
10.
Radioactive Haste Shi in
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At the inspector's reques No items of noncompliance were identified in this area.
ll.
Conduct in Radiolo icall.
Controlled Areas t,
a randomly selected. radioactive waste drum, which had been packaged and made ready for shipment, was removed for inspection.
The lid of the 55 gallon drum, containing solidified evaporator bottoms, was removed and the drum inverted over a plastic mat for 30 minutes.
The inspector observed no water on the plastic mat and no evidence of moisture on the top of the drum.
A licensee representative stated that this type of check for free standing water is routinely conducted about once per calendar quarter.
Throughout the course of the inspection, the inspector made several tours of radiologically controlled areas.
'These included the Auxiliary Building and Reactor Containmen During a tour of the Auxiliary Building, while in a contaminated area, on May 1, 1980, the inspector,.observed two individuals working at the Motor Control Panel (MCC)-1C with their bare hands, having removed their gloves.
The inspector noted that the Radiation Work Permit (RWP No.
1) under which
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the men were working, specified the use of gloves as part of the protective
'lothing requirements.
A licensee representative, on 'learning of the above, immediately -directed the two'individuals to monitor their hands for contamination and to wear. the gloves.
A licensee representative stated
'that the individuals had removed the gloves because the precision work which the individuals were performing made work difficult through the heavy work gloves.
A l.icensee representative later stated that, in the future, such precision work would. be performed by. using gloves more appropriate to such work (e.g
, surgeon's gloves).
The inspector noted that Technical Specification (TS) 6. 11 requires that procedures be prepared consistent wi-th 10 CFR Part 20, and shall be adhered to.
Procedure HP.-4.3,
"Work Permit Use", Revision 14, requires in Section 6.1.5 that each person working under an RWP shall comply with the RWP in all respects.
The inspector noted that the failure to comply with the RWP provisions which specified the wearing of protection gloves as constituting an instance of noncompliance against TS 6. 11 (50-244/80-06-01).
During the remainder of the tour, the inspector observed four instances where individuals were chewing gum while in contaminated/controlled areas, one on the operating level of the Auxiliary Building, and three in the Reactor Containment.
The inspector noted that Procedure A. 1, "Radiation Control Manual", Revision 14, states in part, in Section,VI.A.,
"Access to Controlled Areas", that smoking, chewing, or eating are strictly prohibited in controlled areas.
The inspector noted that the failure to comply with the provisions of Procedure A.l as constituting another instance. of noncompliance against TS 6.11,(50-244/80-06-01).
During a tour. on April 29, 1980., the inspector observed several individuals, at the main step-off pad (egress)
area adjacent to the controlled area, removing,.their contaminated and potentially contaminated protective clothing with their bare hands.
The inspector observed that several individuals would, on egress from the controlled (contaminated)
area, remove their protective gloves, then complete the egress procedure by removing their coveralls and protective shoe covers (both of which were contaminated).
The individuals would then either proceed to the monitor station and check for contamination. or. wash their hands first,. then proceed to the monitor station.
This practice occurred about 50 to 75 percent of the time while the inspector was observing the step-off pad area.
(In all, 18 instances of this practice were observed'bv the inspector.)
The inspector noted that this is poor health physics practice.
The inspector informed the licensee representative
that the general industry practice is to never intentionally touch or handle material which is radioactively contaminated or potentially contaminated, with one's bare hands.'he inspector informed the licensee representative that the commonly accepted procedure entails removal of relatively high contamination articles (e.g.,
shoe covers). while wearing an outer set of protective gloves, then removing these gloves to finish the procedure (e.g.,
removal of coveralls),
using an inner set of protective gloves.
The inspector noted that this practice of intentionally touching contaminated (or potentially contaminated)
material, such as protective clothing, with bare hands, constitutes a deviation from acceptable industry practice (50-244/80-06-02),
Two other observations of note were made during the course of the inspector's tours.
First, while touring the Auxiliary Building on April 30, the inspector observed an individual in a contaminated area inexplicably put his finger in'his mouth while he was wearing his protective gloves.
The inspector informed a licensee health physics representative of this observation, whereupon the individual was immediately instructed to monitor his mouth for contamination.
Ho contamination was subsequently found.
Second, the inspector observed a memorandum to all plant employees from the Supervisor of Health Phvsics and Chemistry, which was posted at the main health physics control point.
The memorandum conveyed the (licensee identified) finding of a recent internal audit that certain individuals, contrary to procedure, had not read and signed their Radiation Work Permit but, rather, had another individual sign their names for them.
The memorandum re-instructed personnel in the procedure for signing in, reading, and understanding requirements of the RWP.
The inspector'informed licensee management that the inspector's observa-tions during facility tours, as stated above, appear to indicate that more attention be directed to the conduct and practice of personnel in radio-logically controlled areas.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on May 2, 1980.
The inspector summarized the scope and findings of the inspection as presented in this repor The licensee representative made the following comments:
With regard to the failure to follow procedures, a memorandum to all personnel would be issued'e-.'instructing them of the requirement (see Paragraph 11); and With regard to the Deviation (see Paragraph 11, also), the requirement for an additional set of, protective gloves will be required by Radia-tion Work Permits and, additionally, worker training will be modified, by May 2, 1980, to instruct workers how to handle contaminated material/
articles on egress from the Controlled Are