IR 05000244/1986004
| ML17251A636 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/24/1986 |
| From: | Dragoun T, Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A635 | List: |
| References | |
| 50-244-86-04, 50-244-86-4, NUDOCS 8604150522 | |
| Download: ML17251A636 (16) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244/86-04 Docket No.
50-244 License No.
DPR-18 Priority Category C
Licensee:
Rochester Gas and Electric Cor oration 49 East Avenue Rochester New York 14649 Facility Name:
Ginna Nuclear Power Plant Inspection At:
Ontario New York Inspection Conducted:
Februar 24-28 1986 Inspectors:
c lw~
.
McFa den, Radiation Specialist T.
ragoun, diation Specialist dat date Approved by:
M. Shanbaky, C ief, Facili ies Radiation Protection Section da e
Ins ection Summar
Ins ection on February 24-28 1986 Ins ection Re ort No. 50-244/86-04 Areas Ins ected:
Routine, unannounced inspection of 'the licensee's radiation protection program during an outage including:
selection and training of personnel, external exposure control, internal exposure control, control of radioactive material and contamination, surveys and monitoring, and ALARA program.
This inspection involved
inspector-hours on site by two region-based inspectors.
Results:
No violations were identified.
Sb04150522 Sb0325 PDR ADOCN, 05000244
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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewed:
1. 1 Licensee Personnel R. Burt, HP Training Coordinator
"D. Filkins, HP and Chemistry Manager
"W. Goodman, HP Foreman R.
Lemmon, Maintenance Foreman
- F. Mis, HP/Radwaste Supervisor R. Morill, Training Manager
"B. guinn, Corporate Health Physicist S. Sagaties, HP/ALARA Supervisor
"S. Spec'tor, Plant Superintendent
- J. Supina, Dosimetry Supervisor/ALARA Coordinator K. Triou, Training Coordinator
- S. Warren, Health Physicist 1.2 NRC Personnel
- W. Cook, Resident Inspector
~T.
Kim, Resident Trainee
"Attended the exit meeting on February 28, 1986 Additional licensee and contractor personnel were contacted during this inspection.
2.0
~Per oee The purpose of this routine inspection was to review the licensee's radiation protection program during an outage with respect to the following elements:
Selection and training of new personnel External exposure control Internal exposure control Control of radioactive material and contamination, surveys, and monitoring ALARA program,
3.0 Status of Previousl Identified Items 3. 1 (Open) Unresolved Item (85-07-01):
Review acceptability of medical evaluations of respirator users by a nurse.
The licensee stated that the corporate physician is providing oversight for this program.
Several options for documenting the physician's review are under consideration.
4.0 Selection and Trainin of New Personnel The licensee's general employee, radiation worker, respirator use and contractor radiation protection technician training programs and the
,licensee's selection criteria for contractor radiation protection technicians were reviewed against criteria contained, in:
CFR 19.12, Instructions to workers
CFR 20.206, Instruction of personnel Regulatory Guide 1.8, Personnel Selection and Training ANSI N18. 1-1971, Selection and Training of Nuclear Power Plant Personnel.
The licensee's performance relative to these criteria was determined by:
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interviewing instructors
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reviewing training materials
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reviewing training records and exams
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reviewing, experience of contractor radiation protection technicians.
Within the scope of this review, no violations were identified.
5,.0 External Ex osure Control The licensee's control of external exposure during an outage was reviewed against criteria contained in:
CFR 20, Standards for Protection Against Radiation Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
Regulatory Guide 8.2, Guide for Administrative Practices in Radiation Monitoring Regulatory Guide 8.7, Occupational Radiation Exposure Records Systems ANSI/ANS-3.2-1982, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants ANSI N13.2-1969, Guide for Administrative Practices in Radiation Monitoring ANSI N13,6-1966, Practice for Occupational Radiation Exposure Records 'System The licensee's performance relative to these criteria was determined by:
observing techniques used to reduce external radiation exposure during the outage activities in containment interviews with licensee personnel independent verification of external dose rates in containment review of external dosimetry records and reports observation of types of external dosimetry used reviewing the planning and preparation for outage activities to involve high external dose rates and the use of current personnel dosimetry data for dose control observation of posting and labeling observation of work in a locked high radiation area and the subsequent securing of this locked high radiation area review of the implementation of the special radiation work permit (SMP) program.
In general,
'the licensee appeared to be providing adequate control of occupational external exposure on such outage activities as testing and repairs on the primary side of steam generators, control rod drive.guide tube split-pin replacement, and repair of regenerative heat exchanger.
But the inspectors did have a concern about the generati,on of SMPs and the interpretation of SWPs by radiation protection technicians.
Although the following two procedures address what a radiation worker must do to comply with a SWP, there is nothing in the procedures which explains how a
SWP is to be generated or how a radiation protection technician is to comply with and complete a
SWP.
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Procedure No. A-l, Radiation Control Manual
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Procedure No. HP-4.3, Health Physics Work Permit Use This lack of specific guidance could result in inconsistencies in the types, frequencies, and documentation methods of surveys.
In fact, review of SWPs used and completed during this inspection revealed inconsistencies in the methods utilized to record survey results.
Based on this concern, the licensee committed to provide documented guidance for the generation of SWPs to those authorized to write SWPs and to provide to radiation protection technicians clear written instructions stating what type of survey documentation methods are required to comply with a SQP as written.
The licensee stated that this action would be completed before the start of the next major outage.
This matter will be reviewed in a future inspection (86-04-01).
Within the scope of. this review, no violation was identifie.0 Internal
'Ex osure Control The licensee's control of internal exposure during an outage was reviewed against criteria contained in:
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CFR 20, Standards for Protection Against Radiation
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Regulatory Guide 1.33, guality Assurance Program Requirements (Operation)
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Regulatory Guide 8.2, Guide for Administrative Practi,ces in Radiation Monitoring
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Regulatory Guide 8.7, Occupational Radiation exposure Records Systems
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Regulatory Guide 8. 15, Acceptable Programs for Respiratory Protection
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ANSI N13. 1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities
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ANSI/ANS-3.2-1982, Administrative Controls and guality Assurance for the Operational Phase of Nuclear Power Plants
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ANSI N13.2-1969, Guide for Administrative Practices in Radiation Monitoring
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ANSI N13.6-1966, Practice for Occupational Radiation Exposure Records Systems
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ANSI Z86. 1-1973, Commodity Specification for Air
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ANSI Z88.2-1980, Practices for Respiratory Protection.
The licensee's performance relative to these criteria was determined by:
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observation of the issuance and use of filter respirators and air-supplied hoods and of the use of personnel enclosures with HEPA-filtered exhaust systems,< ')personnel and general area air samplers, and whole body counting
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interviews with licensee personnel
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review of MPC-hour logs, air sampling results, local mask use check sheets, suppli.ed-air-quality test results, and SWPs.'he licensee appeared to be providing effective control of internal occupational exposure.
Licensee's records indicated that there had not
'een any MPC-hour determinations greater than one during this outage.
Within the scope of -this review, no violations were identifie C
7.0 Control of Radioactive Material and Contamination Surve s and Monitorin The licensee's performance in this area was reviewed against criteria contained in:
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CFR 20, Standards for Protection Against Radiation
CFR 50, Appendix B, guality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
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Technical Specification 6.8, Procedures
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Regulatory Guide 1.33, guality Assurance Program Requirements (Operation)
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Regulatory Guide 8.2, Guide for Administrative Practices in Radiation Monitoring
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ANSI/ANS 3.2-1982, Administrative Controls and guality Assurance for the Operational Phase of Nuclear Power Plants
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ANSI N13. 1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities
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ANSI N13.2-1969, Guide for Administrative Practices in Radiation Monitoring The licensee's performance relative to these criteria was determined by:
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observation of the supply and calibration of survey monitoring equipment in use, the use of portal monitors and friskers, the dates of surveys posted on the radiological status board at the access control point, contamination-control work techniques being practiced, and efforts to reduce contaminated trash accumulation outside of designated storage areas including steps to minimize the introduction of uncontaminated material into contaminated areas
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interviews with licensee and contractor personnel
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review of survey records for adequacy of scope and frequency.
Completed SWP packages were being reviewed by the radiation protection staff on the shift or day following the use of the SWPs.
A SWP package contained as a minimum the SWP sheet and a sign-in sheet.
A SWP package could additionally include:
air sample analysis worksheet, local mask use check sheet, steam generator exposure record, and SWP continuation
'sheet.
This'as the mechanism used by the license to verify that the intent of the RWP was properly carried out.
In addition to updated survey information obtained from the completed SWP packages, the licensee-was also performing routine surveys and special surveys on high dose/high surface contamination activitie At the exit of the protective clothing removal area, the inspectors ob-served that there was a microprocessor-based stand-in personnel contamina-tion monitor near a standard frisking station equipped with a pancake probe and rate meter.
The licensee stated that the automated frisker was on loan from a vendor and undergoing evaluation.
The licensee reported that the automated frisker which contained fifteen large-area independent gas-flow proportional detectors had demonstrated itself to be more sen-sitive than the frisking of an individual performed by a radiation pro-tection technician utilizing a pancake probe and rate meter.
Based on the licensee's interpretation of the use of the stand-in automated frisker as
"under evaluation,"
procedures for its use and calibration had not been established, approved, or implemented.
Following discussions between the inspectors and the licensee, the licensee committed to document the cal-ibration and to establish and implement written instructions for the use and calibration of this stand-in frisker within ten days.
Before the end of the inspection, a calibration record and a written instruction for use had already been generated by the licensee.
This matter will be reviewed in a future 'inspection (86-04-02).
Within the scope of this review, no violations were identified.
8.0 ALARA The per formance of the licensee's ALARA program was reviewed against criteria contained in:
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CFR 20.1, Purpose
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Regulatory Guide 8.8 and 8. 10
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Station Procedure A-l.5, "Keeping Occupational Exposure at Ginna ALARA"
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Station Procedure A-l.6, "ALARA Committee Operating Procedure"
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Station Procedure A-1.6. 1, "Oocumentation of "As Low As Reasonably Achievable (ALARA) Program."
The licensee's performance relative to these criteria was determined from:
Oiscussions with the ALARA Coordinator, Radiation Protection Manager, and radiation protection technicians Reviews of Special'Work Permits and Radiation Work Permits and observation of work in progress'eview of dose tracking reports Observation of an ALARA Committee meetin Within the scope of this review, no violations were observed.
Licensee strengths in this area were noted by the following:
Two dose intensive work efforts were underway during this outage:
removal of split pins from the control rod guide tubes and inspection and repair of steam generator tubes.
The split pin work was performed by Framatome of France using special shielded apparatus.
The steam generator work involved the use'f the Combustion Engineering GENISIS robot arm.
Both work efforts were near completion and estimated to expend approximately 70% of the original ALARA exposure estimates.
The split pin removal involved about 32 man-Rem while steam generator work used about 65 man-Rem.
An ALARA committee meeting was held on February 25, 1986, with senior station management in attendance to discuss a change in the steam generator work scope.
The additional work discussed included machining manway studs and removing tube plugs and sleeving tubes.
The options and ALARA considerations were thoroughly discussed.
The inspectors noted that these efforts demonstrate a good management commitment to the ALARA program.
9.0 Exit Interview The inspectors met with the personnel denoted in section 1. 1 at the conclusion of the inspection on February 28, 1986.
The scope and findings of the inspection were discussed at that time.
At no time during this inspection was written material provided to the licensee by the NRC inspector A
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