IR 05000244/1980013
| ML17257A464 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/24/1981 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17257A463 | List: |
| References | |
| 50-244-80-13, NUDOCS 8107150043 | |
| Download: ML17257A464 (22) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-244/80-13 Docket No.
50-244 License No.
DPR-18 Priority Category C
Licensee:
Rochester Gas and Electric Company 89 East Avenue Rochester, New York 14649 Facility Name:
R.E.
Ginna Nuclear Power Plant Inspection at:
Ontario, New York Inspection conducted:
September 23-26 and November 24-26, 1980 Inspectors:
.E. Plumlee, Radiation Specialist date signed date signed date sig d
Approved by:
napp, se, ac>
'
s Radiation P
tection Section, Technical Inspection Branch date signed Ins ection Summar:
~Ins ection on Se tember 23-26, and. November 24-26, 1980 Re ort No.
50-244/80-13
~Ad:
II i, di p
i ty gi 1b d
inspector of preparations prior to a major maintenance outage, and sub-sequent inspection during the outage, including:
procedures, advance planning and preparations, training, exposure control, posting and control, radioactive and contaminated material control, surveys, independent measurements, and corrective actions on previously identified items.
Areas where work was being conducted were examined to review radiological procedures and practices.
The inspection involved 50 inspector-hours on site by one NRC regional based inspector.
Results:
No items of noncompliance were identified.
~8i07i50043 Si05i8 PDR ADOCK 05000244 gG PDR Region I Form 12 (Rev. April 77)
DETAILS 1.
Persons Contacted a.
RGKE Personnel RJ
%AD
- /
4'*F AWJ AAB ARB
- R Bodine, QC Inspection Engineer Filkins, Supervisor of Health Physics and Chemistry Goodman, Health Physics Foreman Mis, Health Physicist Noon, Assistant Plant Superintendent guinn, Health Physicist Snow, Plant Superintendent Watts, Health Physicist b.
NRC Personnel Present at Exit Interviews
~""D.
Johnson, Acting Senior Resident 'Inspector
""K.
Plumlee, Radiation Specialist
"R.
Zimmerman, Senior Resident Inspector Denotes presence at the close out meeting with licensee management at 2 p.m.,
November 26, 1980.
The meeting was scheduled early to avoid any conflict with a previously announced licensee meeting at 3 p.m.
Inspection of radwaste shipping records continued later in the day.
Denotes presence at the above meeting and a'iso presence at the close out meeting concluding the pre-outage inspection effort, at I p.m.
on September 26, 1980.
""* Denotes presence at the 1 p.m.
September 26, 1980 meeting only.
2.
Licensee Action on Previousl Identified Items (Closed) Inspector Follow Item (78-25-01):
Review the computerized dosimetry record system.
During this inspection the dedicated com-puter system was not maintaining the desired scope of dosimetry records; for example, the licensee maintained the Forms NRC-4 and -5 by hand.
Later the licensee redirected this effort to use a shared computer, located in the Ginna Technical Support Center, for dosimetry records and ALARA records use.
This item will be reviewed on a subsequent routine inspection within the requirements of the routine IE inspection program.
(Closed)
Inspector Follow Item (79-01-01):
Review the durability of portable survey instruments.
Licensee review (preventive action report 6-79) indicated the durability problem was mostly limited to Teletectors.
Licensee corrective action included reinstructing the users on the handling precautions for Teletectors and for survey instruments generally.
Daily pre-use verification checks are required for the portable survey instruments.
No new problems were identified during this inspection (paragraph 5.c)
~
(Closed)
Item of Noncompliance (79-01-02):
Failure to per form a breathing zone air. survey necessary to comply with 10 CFR 20.
103 (a)
(3).
Previous inspection of air sampling was documented in reports 244/79-05 (paragraph 8a)
and 244/80-06(paragraph 7).
The inspector reviewed the completion of corrective actions stated in the licensee letter dated February 28, 1979; and verified that the following procedures were implemented H-S2.3, Revision 5, August 1, 1979, "Incore Thimble Cleaning,"
and procedures HP ll.1, 11.4, 11.5. 1, 11.5.2, 11.5.3, 11. 10, and 11. 11, for which the titles are listed in report paragraph 4.a.
No problems were identified.
(Closed)
Item of Noncompliance (79-01-04):
Inadequate
CFR 19.13 reports to three workers.
Review verified that corrected reports were prepared, dated March 21 or 22, 1979.
Review of recent reports did not identify any problems (paragraph 7.b).
(Closed)
Inspector Follow Item (79-04-04):
Review licensee control of personnel occupancy of radiation areas..
The ALARA requirements are included in worker orientation training and in procedures A-l, A-l.S and A-1.6. 1, see paragraphs 4.a, 6,
and 7.
No items of noncompliance were identified during tours of the facility.
.(Closed)
Inspector Follow Item (79-04-05):
Review control of film badges and TLDs.
Licensee task assignment ELD 79-30 resulted in expanded badge racks and in checking at the control point to improve the control of personnel dosimetry.
No items of noncompliance were identified on this inspection (paragraphs 4.a and 7.a).
(Closed) Inspector Follow Item (79-18-03):
Review procedures for closing up radwaste shipping containers.
Review of current procedures (paragraph 4.b) for radwaste shipping verified the incorpor'ation of procedures for cl'osure of containers of radioactive materials.
No problems were identified (paragraph 10).
(Closed) Inspector follow item (79-18-04):
Review the training of individuals who process and ship radioactive material.
Review verified that the licensee had sent one or more health physics representatives to appropriate off-site seminars or training courses on February 4 and 5, February 6, February 20 and 21, April 14, July 10, and August 7, 1980, however, no written program had been formulated 'to train or qualify that level of personnel on NRC and DOT radioactive materials transport.
This item will be inspected within the requirements of the routine IE program of inspection of transportation activities.
Licensee training of operators who were involved in waste solidification:
was incorporated into operator and systems training procedures A-102.6 and A-102. 14, these records being kept, by the training coordinato (Closed)
Item of Noncompliance (80-06-01):
Failure to adhere to procedures.
The inspector toured the facility on several days and observed compliance with RMP clothing instructions and acceptable industry practices.
Specifically no failures to wear gloves while working on RMPs requiring gloves, and no smoking, eating, or gum chewing in controlled areas, was'identified
. Licensee corrective actions, documented in a letter dated August 7, 1980, appeared to be fully implemented.
(Closed) Deviation from Industry Practice (80-06-02):
Intentionally handling contaminated material without gloves.
The inspector observed that during this inspection the removal of protective clothing was not being performed bare-handed see item 80-06-01 above.
3.
Closeout Action on IE Bulletins and Circulars
,
(Closed)
IE Circular 76-03 Followup (Radiation Exposures in Reactor Cavities) Inspections 244/76-22 (paragraph 6) and 244/79-01(paragraph 2 ). documented the implementation of commitments made in the licensee-letter dated November ll, 1976 replying to IE Circular 76-03.
On this inspection the inspector toured the facility and verified the controls by observation and by interviews with personnel.
No fail'ures to identify, post, or lock high radiation areas were identfieid and the licensee commitments on this item appeared to be fully implemented.
Review of Radiation Protection Procedures in Effect Durin the
~Outa e
Part of the inspection effort was to review the availability and adequacy of licensee procedures, and adherence to procedures, during the maintenance outage involving the presence of several hundred temporary workers.
a.
Routine Procedures The inspector reviewed the following procedures and verified adherence to the procedures by observation, by interview with personnel, or by record reviews, as applicable.
Procedure Number Title A-1 A-l.1 A-l.5 A-1. 6. 1 Radiation Control Manual Locked Radiation Areas ALARA Occupational Exposure Documentation of ALARA Program
Procedure Number Title A-3 A-54.6 A-102.3 A-102.10 HP-1. 1 HP-1.2 HP"1.3 HP-2. 1 HP 2.2 HP-3. 1 HP-3.2 HP"2.3 HP"2.5 HP-4. 1 HP-4.3 HP-5.1 HP-5.2 HP-6. 1 HP-6.2 HP-11. 1 HP-11.4 HP-11.5. 1 HP"11.5. 2 Containment Access Health Physics Tour (weekly)
Health Physics Orientation Program Health Physics Training and Responsibility Limits Issuing Personnel Oosimetry External Exposure Limits External Exposure Records Whole Body Counting Guide Whole Body Count Operation Exposure Reports to Individuals and the NRC In-Plant Reportigg of Current Exposures TLD Reader Calibration Whol e Body Count Eval uati on Controlled Area Entry Work Permit Use Area Radiation Surveys Posting of Radiation Areas and Container labelling Contamination Surveys Posting of Contaminated and Airborne Areas Iodine in plant-air drying tube method High volume air sampling NMC Constant air monitor AM-3D calibration NMC Constant air monitor AM-21 Calibration
Procedure Number Title HP-11.5.3 HP-11.10 HP-11.11 HP"12.1 HP-12. 2 HP-12. 3 HP-12. 4 HP-12.6 NMC Constant air monitor AM-22 I calibration Air sampling with SIERSAT low volume air samplers Gas sampling and analysis utilizing a 35 cc glass bulb Usage of Resp) rator s Medical Checks, Fitting and Training of Personnel Using Respirators Sel ection of""respirators Fitting and testing of Respirators Issuance Proper use and Return of Respirators No items of noncompliance were identified.
b.
Trans ort Procedures The inspector verified by interview with the health physicist assigned the responsibility for transport procedures, and by review of records of shipments, that the following procedures have been implemented.
A survey of a shipment was verified and closures of 55-gallon drums were verified.
Procedure Number No.
Revision Date Title abbreviated M 18.6 4/18/80 Handling, loading and un-loading of CNSI Transport Cask CNS-8-120 Model LL-50100.
QCIP-21 RD-9 RD-10 RD-10.1 1/31/80 2/10/79 2/28/79 4/18/80 Shipping Package CNS 8-120 Inspection Preparing waste for ship-ment or storage Shipping radioactive material RG&E Radioactive material shipment record forms
RD-10. 4 4/9/80 Radwaste shipping to NECO at the Beatty Nevada Site RD-10.4. 1 RD-10.4. 2 RD-10.4. 3 4/9/80 4/9/80 4/9/80 NECO Radioactive Shipment Record (RSR)
NECO Certification Form State of Nevada Certification Form S"4.1.25 10/6/80 Checking drums for free standing liquids No failures to adhere to procedures were identified.
The inspector noted that none of the above procedures appeared to address the road worthiness of the vehicle and this was brought to the licensee's attention (paragraph 10).
5.
Advance Plan@in and Pre aration a.
Increased Health Ph sics Staff Three contract personnel were hired before the outage to plan out and set up for the major jobs.
Eight senior and four junior contract technicians and clerks were hired for the outage.
Review of the resumes of eleven of the above individuals did not identify any lack of qualification in accordance with ANSI-N 18. 1, 1971, "Selection and training of nuclear power plant personnel",
requirements for technician in responsible positions.
Review of selected records independently verified that the above resumes were consistent with the actual times spent at various facilities (see paragraph 6.c. ).
b.
Mocku s and S ecial Trainin The inspector noted that contract personnel generally were selected and assigned to jobs on which they had prior experience on site or at similar facilities.
The licensee maintained mockups and spare units on which per-sonnel were trained for steam generator entries and maintenance of plant component c.
Su lies and E ui ment The licensee appeared to maintain adequate stocks of protective clothing, respiratory equipment, decontamination materials and special equipment necessary for the outage.
Automatic restock procedures were in use for protective clothing and gloves.
Review of the availability of health physics instruments as of September 24, 1981 showed that the following 100 instruments were available and another 9 instruments were out of service, needing repair.
Of the total of four Teletectors, two were usable on that date, and this was 50% availability as com-pared to the 85% availability of the remaining 35 portable beta-gamma survey instruments and the overall 91% availability of the 109 instruments.
T e of Instrument Usable Out of Service Portable beta-gamma survey Telectors Others
'
Friskers
none Air Samplers and CAMS
Area Monitor instruments
Others (Alpha and Neutron)
none As documented in paragraph 2, item 79-01-01, the licensee has established training of the user s in the handling precautions necessary with portable survey instruments.
No new problems with equipment availability were identified, Trainin of New Arrivals on Site a.
Indoctrination Trainin The inspector interviewed a few individuals and each stated he had received indoctrination training on arrival.
The inspector witnessed training and no omissions of inform-ation required by 10 CFR 19. 12 were identified.
The inspector verified that records were maintained of this trainin b.
RWP ualification Trainin The inspector interviewed a few individuals whose records indicated they were RWP qualified and each stated he had received training and passed a written examination.
C.
Review of training curricula attendance, and examination records did not identify any problems.
Contract Health Ph sics Technican Site-S ecific Trainin and uglification Review of qualification scores of health physics technicians described in paragraph 5.a, indicated that a few of the apparently more experienced individuals required remedial action, or barely passed, but there was no obvious explanation for their relatively marginal scores.
Less experienced individuals did not appear to have marginal or failing scores'he licensee representative stated that their job performance was acceptable.
Interviews with these individuals, and observation of their work, did not identify any marginal or unacceptable level of knowledge of the job.'o items of noncompliance were identified.
Ex osur e Control Wearin the Assi ned Dosimetr Devices The inspector observed that the workers continue to be required to pick up their assigned badges, unassisted, as they pass the badge rack in the badge housel'eview of radiation work permits did not identify any inadequate dosimetry selections'bservation during entering and exiting the facility and during facility tours did not identify any failure to wear the assigned dosimeters.
b.
Dosimetr
.Records Review of dosimetry records did not identify any errors, failure to prepare Forms NRC-4 and NRC-5, or failure to report exposures to workers on termination in compliance with 10 CFR 19.13 and
CFR 20.408.
C.
Review of Personnel Ex osure Authorization The inspector selected 10 individual's files for record review.
Completed Form NRC-4's were identified in each fil i
No examples were identified of exposure in excess of 10 CFR 20.101 limits and conditions.
No examples were identified of failure to follow guidance in licensee procedure A-l, "Radiation Control Manual", which requires, during refueling, specific authorization to exceed 200 mrem/day, 500 mrem/seven consecutive days, and 2,000 mrem/calender quarter, 8.
Review of Res irator Protection Pro rams
'a
~
Adherence to Internal Ex osure Limits Observation of working conditions during the inspection, and review of records of work permits, air samples, contamination surveys, nasal swipes, skin contamination, and whole bodycounts did not identify any exposure to airborne radioactive materials in excess of 10 CFR 20. 103 limits.
b.
Tem orar En ineerin Controls C.
The inspector verified that exposures to airborne radioactive materials were controlled by decontamination of the surfaces, use of plastic covers and tents to prevent spreading contamination, and use of controlled ventilation systems to prevent exposures to unacceptable concentrations of airborne radioactive materials.
Licensee Evaluations of Controls The inspector noted that the records of the licensee evaluations appeared to verify the selection of acceptable equipment, the use of authorized protection factors, the application of preventive measures, and the evaluation of internal exposures.
d.
Res irator Protection Trainin and Res irator Fittin and Testin The inspector verified (paragraph 7.c) that the medical check, fitting and training of personnel using respirators was doc-umented and the procedure, HP-12.2 (paragraph 4.a),
appeared to be fully implemented.
. Observation of training and fitting did not identify any problems in the qualification of users of respirators.
e.
Res irator Cleanin and Maintenance The inspector observed the collection process for used respirators, and respirator cleaning and maintenance.
The inspector observed the users as they checked the respirators before they were donned and as they tested the respirator fit each time the respirator was donned.
No problems were identifie ~
~
I 9.
Postin and Control of Radiation Areas Airborne Radioactivit Areas and Contaminated Areas The inspector toured the facility on several days of the inspection and verified the adequacy of posted information, confinement, and survey information.
The inspector also surveyed the outdoor radioactive waste storage area fence and a trailer being loaded with material to be transported.
No items of noncompliance were identified.
10.
Radioactive and Contaminated Materal Control The inspector observed the licensee's management of used protective clothing, contaminated trash, and radioactive waste.
In addition to the verification of survey information and posted information, described above, the inspector verified container labels, transport information and shipping documents.
The inspector reviewed the records of the following shipments (see paragraph 4.b for list of applicable procedures):
1980 shipments nos.
3, 5, 34, and 35 to 39.
The inspector noted that the applicable procedures appeared to be fully.implemented.
The inspector noted that none of the above records appeared to address the road worthiness of the tractor and trailer used to transport radioactive materials.
(see below)
11.
Exit Interview Interviews were conducted on September 26 and on November 26, 1980, with the personnel denoted in paragraph 1, to review the inspection findings.
Survey instrument availability was reviewed (paragraph 2, item 79-01-01).
Radioactive waste shipping was discussed (paragraphs 4.b and 10).
The licensee representative stated that a temporary change notice would be provided addressing transport vehicle road worthiness.
Licensee commitments were reviewed, paragraph 2.
The licensee plans to persist in improving the computerized dosimetry records syste ~
~