IR 05000244/1981007
| ML17258B174 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/18/1981 |
| From: | Knapp P, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17258B171 | List: |
| References | |
| 50-244-81-07, 50-244-81-7, NUDOCS 8107100261 | |
| Download: ML17258B174 (17) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-244/81-07 Docket No.
50-244 License No.
DRP-18 Priority Category Licensee':
Rochester Gas and Electric Com an 89 East Avenue Rochester New York 14649 Facility Name:
R.
E. Ginna Nuclear Power Plant Inspection at:
Ontario, New York Inspection conducted:
March 22-26, 1981 Inspectors:
R.
L. Nimitz, Radi ion Specialist date signed Approved by:
P.
.
Knapp, Chic, Facility Radiological Protection Section date si ned Ins ection Summar Ins ection on March 22-26 1981 Re ort No. 50-244/81-07 Areas Ins ected:
Routine, unannounced inspection of the licensee advanced planning and prepar ation for the outage, including: posting and control; radioactive and contaminated material control; training; advanced planning and preparation; respiratory protection; and personnel monitoring devices.
Upon arrival on site at 8:30 p.m.
on March 22, 1981, areas where work was being conducted were examined to review adherence to radiological control procedures and practices.
The inspection involved 30 inspector-hours on site by one regional based inspector.
Results:
Of the six areas inspected, no items of noncompliance were identified in five areas, one item of noncompliance was identified in one area (Failure to utilize respiratory 'protective equipment in accordance with Regulatory Guide 8.15 as required by
CFR 20.103(c),
Paragraph 6.)
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DETAILS 1.
Persons Contacted E. J. Beatty, Special Projects co-ordinator
- D. E. Filion, Radiochemist
- D. L. Filkins, Supervisor, Health Physics and Chemistry
- W. P.
Goodman, Health Physics Foreman
"E. Gordon, Health Physicist
"F. Mis, Health Physicist R.
W. Morrill, Training Co-ordinator
- J.'. Noon, Assistant Plant Superintendent
- C. H. Peck, Operations Engineer
- 8. guinn, Health Physicist M. Sexton, Shift Supervisor
- B. A. Snow, Plant Superintendent NRC Attendees at Exit Interview J. J.
Kottan, USNRC Region I J.
C. Jang, USNRC Region I R.
P.
Zimmerman, Resident Inspector
- denotes those persons present at exit interview on March 26, 1981
"~contacted via telecon during exit interview The inspector also talked with and interviewed several other licensee employees, including members of the chemistry and health physics staff, and reactor operations and maintenance personnel.
2.
Postin and Control The inspector toured the controlled areas upon initial arrival and at various times during the inspection.
Radiation intensity measure-ments were performed to verify licensee's compliance with the requirements of 10 CFR '20.203,
"Caution signs, labels, signals and controls,"
and Technical Specification 6.13,
Also reviewed was licensee adherence to the following procedures:
Procedure A-l.l, Revision 10, "Locked High Radiation Areas,"
dated February 25, 1981 Procedure HP-5.1, Revision 8,
"Area Radiation Surveys,"
dated February 23, 1981 Procedure HP-5.2, Revision 2,'Posting of Radiation Areas,"
dated June 14, 1979 The inspection tours indicated Radiation and High Radiation Areas are being posted, barricaded and/or locked in accordance with the above requirements.
No items of noncompliance were identified in this area.
3.
Radioactive and Contaminated Material Control The inspector toured the controlled areas and reviewed licensee c'ontrol of radioactive and contaminated material with respect to the following:
CFR 2.203,
"Caution signs, labels, signals and controls" Procedure HP-5.2, Revision 2, "Posting of Radiation Areas and Container Labeling," dated June 14, 1979 Procedure HP-6.2, Revision 3, "Posting of Contaminated and Airborne Areas," dated January 30, 1980 The inspection tours indicated radioactive and contaminated materials were controlled in accordance with the above requirements.
No items of noncompliance were identified in this area.
4.
~Trainin a.
Radiation Worker Trainin The inspector audited the licensee's radiation worker training program for conformance to
CFR 19.12, "Instructions to Workers,"
and licensee Procedure A-102.3, Revision 0,
"R.
E.
Ginna Health Physics Orientation Program,"
dated January 22, 197 The audit of the radiation worker training indicated the program met the above requirements.
The inspector noted, however, that the worker training in radioactive surface contamination and potential hazards from this contamination were given limited discus'sion during the training session.
The inspector discussed this area with members of the licensee's training and radiation protection staff who indicated the radiation worker training program would be revised by April ll, 1981 to include additional discussion relating to surface contamination.
No items of noncompliance were identified in this area.
Contractor Radiation Protection Technician Trainin and uglification The inspector reviewed the general content and scope of the licensee's contractor radiation protection technician training and qualifying program with respect to Procedure A-102'0, Revision 4, "Health Physics Technician Training and Responsibility Limits," dated December 22, 1980.
The review indicated the licensee is utilizing the selection criteria of ANSI-N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel."
Contractor radiation protection technicians are trained to meet the plant health physics, administrative and respiratory protection requirements.
Review of the procedure indicated the contractor technician must read the procedures pertaining to the tasks that are to be performed.
The technician's ability to follow the procedure is then observed.
The inspector noted, however, this review was performed by a plant technician.
The inspector discussed the above technician review with licensee radiation protection representatives who acknowledged that because some contractor technicians would be acting in responsible positions, such as when performing surveys to ensure compliance with regulatory requirements, Procedure A
102. 10 would be revised by April ll, 1981 to require supervisory review and approval of contractor technician demonstration of satisfactory performance and knowledge of procedure No items of noncompliance were identified in this area.
5.
Advanced Plannin and Pre aration The inspector reviewed the lic'ensee's planning and preparation for the upcoming outage in the area of radiation protection.
The following was noted:
In preparation for non-destructive testing of reactor coolant pumps, the licensee constructed a full scale model of the pump.
The model, located in the facility'
turbine building is used for training and equipment testing purposes.
Because'the testing of the reactor coolant pump will involve use of a linear accelerator, the licensee. sent radiation protection representatives to the accelerator supplier's facility to review set-up and operation of the accelerator.
This was done to determine and plan for radiological hazards which may be encountered during the testing.
The licensee held a utility meeting on March 17, 1981 to discuss the planning and preparation of the reactor coolant pump testing.
Inspector a tendance at this meeting indicated-the licensee planned each major task associated with the coolant pump work and calculated man-rem estimates for these tasks.
ALARA planning is to be used to reduce personnel exposure where possible.
The licensee had constructed a full scale model of a steam generator water box.
.The model is used for training personnel and equipment set-up testing.
During training using the model, personnel were noted to utilize air-supplied respiratory protection equipment during their training entries into the water box.
The licensee plans to augment his radiation protection group with approximately 20 contractor radiation protection technicians.
The licensee will select and utilize the contractor technicians in accordance with ANSI-N18.1-1971 recommendations.
No items of noncompliance were identified in this are.
Res irator Protection The inspector reviewed selected portions of the licensee's respiratory protection program with respect to the requirements of 10 CFR 20.103,
"Exposure of individuals to concentrations of radioactive materials in air in restricted areas."
CFR 20.103(c) requires that when respiratory protective equipment is used to limit the inhalation of airborne radioactive material and allowance is made for use of such equipment, the equipment must be used as stipulated in Regulatory Guide 8.15,
"Acceptable Programs for Respiratory Protection."
The licensee was noted to routinely make allowance for the use of respiratory protective equipment in cases where it is impractical to apply process or other engineering controls.
a.
Stora e
and Re air Regulatory Guide (R.G.) 8.15 Section C.4.d, requires the licensee to maintain and implement a respiratory protection program that includes, among its required elements, written procedures for maintenance to ensure full effectiveness of respiratory protective equipment, including procedures for cleaning and disinfection, decontamination, inspection, repair, and storage.
NUREG-0041, Chapters 9 and 10, is referenced in R.
G. 8.15 as a source of further guidance for implementation of R.
G. 8.15.
NUREG-0041 states in Chapter 9.3 that "respirators are.to be packed or stored so that they are not damaged by adjacent equipment or twisted out of their normal configuration by improper storage".
During a tour of the licensee's respirator facility (lower elevation, Intermediate Building) on March 18, 1981, the inspector noted respiratory protective equipment (full facepiece equipment including welding facepieces)
to be stored stacked in layers up to 5 facepieces high.
The inspector noted the welder facepiece to weigh approximately 3-4 lbs.
and that this stacking of masks could result in deformation of respirator facepieces, particularly if the welder facepieces were stacked on top.
The inspector noted that the licensee's respirator maintenance procedure, HP-12', Revision 1, indicates that respirators are to be stored in labeled areas or bins.
However, the procedure provided no guidance for storage to preclude deformation of respirator facepiece Inspector review of respirator maintenance and repairs and discussions with licensee representatives indicated maintenance and repair of the respiratory protective equipment used by the licensee was performed in accordance with procedure HP-12.5, Revision 1, "Maintenance of Respirators."
Review of procedure HP-12.5 indicated general guidance was provided for decontamination and inspection of the, respirator facepieces used by the licensee, however, no specific instruction relative to repair of these respirators was included in the procedure.
The procedure did indicate repair was to be performed by trained personnel while self-contained breathing apparatus repair was to be performed by the manufacturer.
ualit Assurance The inspector reviewed the licensee's Quality Assurance (QA)
program for respiratory protective equipment.
As previously noted, Section C.4.d. of Regulatory Guide 8.15 requires that written procedures for inspection of respiratory equipment are to be maintained and implemented.
"Manual of Respiratory Protection Against Airborne Radioactive Materials," referenced in. Regulatory Guide 8.15, indicates (Chapter 10) that a proper and complete Quality Assurance (QA) program must encompass inspection and testing-of both new and used devices.
The review of the licensee's respiratory equipment QA program indicated no program or procedures existed for QA of new equipment.
The inspector identified recently purchased equipment (airline breathing hose)
which was to be used for steam generator work that was not an approved type.
The equipment which was being used for training purposes, at the time of the inspection, was of improper length.
The length of the hose was not the same as that which the air supplied hood was approved under.
In addition, during review of QA of used equipment.
the inspector noted that neither the respirator maintenance procedure (HP-12.5) nor the issuance procedure (HP-12.6) specifically prohibited interchanging of respirator components.
Such an interchange would invalidate the device approval.
Review of devices in use indicated the licensee was utilizing high efficiency filter cartridges with air respirator facepieces which were
not approved for use with these cartridges (this is further discussed below).
C.
Use of A roved Devices Regulatory Guide 8.15 requires in Section C.5 that the licensee use respiratory protective equipment approved under the appropriate Approved Schedules in 30 CFR 11 of the U.S.
Bureau of Mines/
National Institute for Occupational Safety and Health regulations.
Review of equipment being used by the licensee indicated that an Acme full face mask (facepiece No. 4704)
was being used with a Scott high efficiency filter (part No. 502R).
Inspector review of dust, fume, and "mist respirator approvals, under which this respirator would be approved (TC-21C) indicated no approval was in place for this combination facepiece and filter
.
The inspector noted that the equipment approved under two separate approvals (TC-19C-71 and TC-21C-149)
had been interchanged.
This resulted in the voiding of the equipment approvals.
Discussion with licensee radiation protection personnel indicated that respiratory protection allowance had been routinely made for the use of the non-approved facepiece/filter combination.
d.
Breathin Air Su
As previously noted, Regulatory Guide 8.15, Section C.4.d; requires implementation of procedures for maintenance of respiratory protective equipment to ensure full effectiveness of the equipment.
Inspector review of licensee preparation for the upcoming steam generator work indicated an electric compressor system was to be used to provide breathing air to workers using air supplied equipment.
The compressor provided the air to the containment air dryer tank which was to act as an air reservoir in the event of compressor failure.
The air was provided to workers through an air-purifier (Del-Monox).
Review of procedure HP-12.7, Revision 2, "Constant Flow Breathing Air System Set-up" indicated that it provided general guidance for set-up of the breathing air system, however, it provided no guidance relative to preventive maintenance of the system in accordance with manufacturer's instructions.
This included such items as periodic inspections, filter changes, pressure gauge tests, et Breathin Air ualit and uantit Regulatory Guide 8.15, Section C.8, provides additional technical items to be observed by licensees who utilize respiratory protective equipment.
Section C.8.a requires that respirable air of approved quality and quantity be provided and oxygen deficient air is to be avoided.
Guidance for air quality and quantity is presented in NUREG-0041, which is referenced in Regulatory Guide 8.15.
NUREG-0041 specifies Grade "0" air, as described in "Commodity Specification for Air," G-7.1-1966, be considered as the limit for air of deteriorating quality.
Included in the quality guidance are limits for oxygen, condensed hydrocarbons, carbon monoxide and carbon dioxide.
Also included is the requirement that breathing air have no pronounced odor.
Review of procedure HP-12.7, Revision 2, "Constant Flow Breathing Air System Setup," indicated signoff requirements were included in the procedure for the above items excluding pronounced odor.
The inspector reviewed several past completed signoffs and noted no indication that a test for odor was included.
The inspector discussed the above with licensee radiation protection representatives and indicated records are required to be maintained as required by Regulatory Guide 8.15, Section C.4.g, to permit periodic evaluation of the adequacy of the respiratory equipment including evaluation of breathing air.
Review of periodic tests indicated that excluding the pronounced odor test, which did not appear to have been performed, the breathing air met Grade "0" specifications.
Ouring review of procedure HP-12.7, the inspector determined that the licensee's procedures provided no guidance relative to maximum allowable flow to be provided to a respirator.
The inspector noted that NUREG-0041, Section 5, references Bureau of Mines/NIOSH requirements that limit maximum airflows to respiratory protective equipment.
The inspector discussed the above with licensee radiation protection representatives who indicated a review will be performed to ensure equipment is not supplied air in excess of
allowable 1 imits.
This item i s considered unresolved.
(50-244/81-07-02)
The inspector discussed the above findings with licensee representatives and indicated that:
1)
failure to repair, store, inspect and maintain respiratory protective equipment in accordance with Regulatory Guide 8. 15, Section C.4.d; 2)
failure to utilize approved respiratory protective equipment in accordance with Regulatory Guide 8.15 Section C.5; and 3)
failure to perform and document all breathing air test requirements in accordance with Regulatory Guide 8.15 Section C.4.g.
and C.8 was noncompliance with 10 CFR 20.103(c)
(50-244'/81-07-01).
Personnel Monitorin Devices During tours of the controlled area, the inspector noted workers, some on the same job, to be wearing their dosimetry devices outside their protective clothing while others were wearing the devices inside their protective clothing.
This situation was also noted in the primary containment.
The dosimetry devices used by the licensee (TLD Badges)
have "beta-windows" which allow monitoring of low energy beta radiation.
Monitoring of this radiation is performed to determine the non-penetrating (skin) dose of an individual in those instances where the skin is not shielded from beta radiation.
The inspector noted that if a covering is placed over the badge, e.g., coveralls, in situations where a worker has portions of his body exposed to beta radiation, the capability of the badge to accurately measure this type of radiation is significantly reduced.
The inspector discussed the above with licensee radiation protection personnel and indicated that the badges should be worn by the individuals in the appropriate position to most accurately reflect the actual skin dose received.
The inspector indicated that on some jobs, such as steam generator work, the badge should be worn inside protective clothing because the protective clothing would serve to reduce the actual beta skin dose received by the worker.
On the other hand, the inspector indicated that on jobs where the potential for skin dose exists and an individual has exposed skin surfaces, the badge should be worn outside the individual's coveralls.
The inspector noted that, based on workers wearing their dosimetry inside and outside their protective clothing on the same job, no apparent direction had been given the workers relative to proper placement of the TLD badge for monitoring skin dose.
The inspector
noted that licensee Health Physics Procedure H.P.-4.1, Revision 6,
"Controlled Area Entry," did indicate in section 6.3 that the "film and TLO must be fixed so the beta window is facing out."
However, this section also indicated that the film and TLO should be protected from contamination.
No guidance was contained in this procedure relative to the type of protection to be provided.
As a result of the above, licensee radiation protection representatives indicated that although there were no apparent beta radiation problems encountered during routine work, they would instruct workers by April ll, 1981 to wear their TLO badges outside their pro'tective clothing except for those jobs where no skin surface is exposed.
The inspector acknowledged the above and noted that it may not be necessary, based on the radiation present, for an individual to wear his TLO badge outside his protective clothing at all times.
The inspector indicated that regardless of what actions are taken, it was the licensee's responsibility to e'nsure that accurate personnel dose determinations are made.
Action taken by the licensee will be reviewed during a future inspection.
(50-244/81-07-03)
8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
One unresolved item is discussed in paragraph 6.e.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on March 26, 1981.
The inspector summarized the purpose and scope of the inspection:
Licensee representatives made the following comments:
with regard to the radiation worker training program, the program will be revised by April 11, 1981 to provide additional discussion of surface contamination hazards.
with regard to radiation protection technician training, procedure A 102. 10 will be revised by April ll, 1981 to provide supervisory level sign-off of technician performance and knowledge of applicable procedure.
with regard to use of personnel monitoring devices, by April 11, 1981 personnel will be required to wear badge dosimetry outside protective clothing for monitoring exposed skin surfaces.
use of protection factors'or respiratory protective equipment is suspended pending review, revision and upgrading of certain aspects of the.respiratory protection progra,c C