IR 05000244/1986010
| ML17251A780 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/21/1986 |
| From: | Mcfadden J, Shanbaky M, Tuccinardi T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A778 | List: |
| References | |
| 50-244-86-10, NUDOCS 8608290075 | |
| Download: ML17251A780 (22) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION Region I Report No.
50-244/86-10 Docket No.
50-244 License No.
DPR-18 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 Inspectors:
Inspection Conducted:
Jul 14-18 1986 dc. C c-c c-c ~-c ~ ~
J.
McFadden, Rad>atio Specialist
~CC,~@en.~~
. Tuccinardi, Radiation Specialist
/z(44 date date Approved By:
M. Shanbaky, Chief, Facil ies Radiation Protection Section date Ins ection Summar:
Ins ection on Jul 14-18 1986 Ins ection Re ort No.
50-244/86-10 AAIA d:
R i, di i
f protection program, including:
status of previously identified items, organiza-tion and management controls, training and qualification of personnel, and con-trol of radioactive materials and contamination, surveys and monitoring.
Two regionally-based inspectors were onsite for the inspection.
Results:
No NRC-identified violations were noted.
I 8608290075 860821 PDR ADOCK 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 J.
Brown, gA Specialist D. Bryant, gA Engineer B. Butler, Training "Instructor J. Catlin, Environmental Tech Trainee D. Fi lion, Radiochemist
- D. Fi lkins, Manager-Health Physics/Chemistry
- W. Goodman, HP Foreman R.
Kenyon, Radiation Protection Technician C. Kimball, Sr.
gA Specialist (Contractor)
R. Morill, Training Manager K. Nassauer, gC Supervisor P. Polfleit, Radiation Protection Technician
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B. guinn, Corporate Health Physicist P.
Spacher, Health Physicist
- S. Spector, Superintendent-G!nna Production
.~ S. Warren,,Health Physicist
- Attended the exit meeting on 'July 18, 1986.
Additional licensee personnel were contacted during this inspection.
1.2 NRC Personnel Attendin the Exit Interview B. Hillman, Reactor Engineer, RI T. Kim, Resident Inspector Trainee 2.0
~Pur ose R
The purpose of this routine inspection was to review the licensee's radia-tion protection program with respect to the following elements:
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Status of previously identified items Organization and management controls Training and qualification of personnel Control of radioactive material and contamination, surveys; and monitoring f0
3.0 Status of Previousl Identified Items Closed Followu Item 84-12-01
The objectives and scope of audits performed by the corporate gA organization for the NSARB need improve-ment to allow for identification of program weaknesses for management
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attention.
In particular, audits of the qualifications and training of the health physics personnel should be reviewed for compliance with applicable technical specifications.
The licensee stated that the conduct of gA audits was under review and would be revised as
'required.
During NRC Inspection No. 86-10, corporate audits 85-59 and 86-09 were reviewed.
The audit checklists had been revised and appeared to be extensive.
Audit No
~ 85-59 specifically addressed personnel qualification and training.
Based on these findings, this item is closed.
3.2 Closed Unresolved Item 84-12-03
An effective ALARA program has been implemented by the station HP organization.
However, during the 1983 outage, certain work involving significant man-rem exposure was directed by corporate management, and the ALARA reviews at the cor-porate level were not documented.
Corporate ALARA review, using guidance provided in a 1978 office memorandum, was conducted infor-mally.
The licensee planned to develop and implement a formal cor-porate-level ALARA commitment.
During NRC Inspection No. 86-10, the inspector reviewed the licensee's corporate
"ALARA Policy" procedure which had an approval date of January 9,
1986.
This 'policy procedure identified the mechanism ("ALARA/Radiation Safety Design Review" engineering work procedure)
to be used for performing ALARA reviews at the corporate level.
The minutes of a Corporate ALARA Review Committee meeting (February 24, 1986) were also reviewed.
Based on this review, this item is resolved and closed.
3.3 3.4 Closed Followu Item 85-01-01:
The following two areas of respon-sibility, held by the Radioactive Waste Coordinator, are not stated in Administrative Procedure No. A-201, "Ginna Station Administrative and Engineering Staff Responsibilities":
(1) receipt of radioactive material and,(2)
shipment of radioactive material other than radwaste.
During NRC Inspection No. 86-10, Administrative Procedure No. A-201, with an effective date of September 25, 1985, was reviewed.
The two areas of responsibility, previously mentioned, have been added to those assigned to the Radioactive Waste Coordinator.
Based on this finding, this item is closed.
Closed Unresolved Item 85-07-01:
Personnel receive a medical evaluation by a specifically trained nurse prior to participation in the respirator program.
This evaluation consists of a medical history questionnaire, blood pressure and spirometry tests.
Only personnel with some contraindication for respirator use are referred to the company physician for evaluation.
The remainder are certified by the nurse.
Regulation
CFR 20. 103(c)(2) states that a "determination by a physician... that the individual user is physically able to use
the respiratory protective equipment" is required.
The licensee stated that the acceptability of determinations made by a nurse would be reviewed.
During NRC Inspection No. 86-04, the licensee stated that the corporate physician is providing oversight for this program.
Several options for documenting the physicians review were being con-sidered.
During NRC Inspection No. 86-10, Procedure No.
HP-12',
"Medical gualification, Training, and Supervision for Personnel Using Respiratory Protection" was reviewed.
This procedure was effective on July 17, 1986.
This procedure states the following:
that the medical director is responsible for the medical "qualification" aspect of the respiratory protection program; that the nurse is responsible for carrying out the medical qualification requirements while under the instructions or direction of the medical director; that a medical questionnaire must be completed by prospective respirator users; that blood pressure and pulmonary function be checked by qualified medical director; and"that any "yes" answers on specific parts of the medical questionnaire require an evaluation by a member of the medical staff under the direction/supervision of the medical director or the medical director himself.
In addition, the licensee stated that the medical director has provided to the nurses, instructions for carrying out the medical qualification requirements.
Based on these findings, this item is closed.
3.5 Closed Followu Item 85-07-02
The computer program used to analyze the whole body counting data was updated to provide information on the location of deposits in addition to radionuclide and quantity.
The current operating procedures for the whole-body counter did not clearly provide the technician with the steps necessary to obtain information on the location of deposits.
The licensee stated that the applicable procedures would be clarified.
During NRC Inspection No. 86-10, Procedure No. HP-2.2,
"Whole Body Counter Operation",
was reviewed.
The procedure reviewed had an effective date of April 16, 1985.
This procedure contained instructions necessary to obtain a
count profile over the length of the body and contained an example profile.
Based on this finding, this item is closed.
3.6 Closed Fol lowu Item 85-18-01:
Licensee audits of the Radio-logical Environmental Monitoring Program (REMP) for 1984 and the first half of 1985 consisted of check-off sheets of activities for the REMP which covered sampling locations, verification of sampler operation and sampling frequencies as specified in the technical specifications.
However, these audits appeared limited in scope in that they did not address certain significant program activities.
Licensee representatives stated that the audit of the REMP is under current revision and that future audits will be more comprehensive and thorough in technical depth for the REMP.
During NRC Inspection No. 86-10, Corporate Audit No. 85-59 was reviewed.
The licensee stated that the audit checklist had been revised to be more com-prehensive than in the past.
In addition to compliance with Tech-nical Specifications, Audit No. 85-59 addressed, procedures and quality control.
Based on these findings, this item is close.7 Closed Noncom liance Item 85-18-03
No written procedure for the calibration of the Baird Low Activity Counter had been established, and four other procedures including HP-10.9, HP-10.5, CP-250, and CP-251 did not specify the frequency for the calibration and adjustment of the equipment to maintain accuracy.
During NRC Inspection No, 86-.10, the inspector reviewed the licensee's corrective actions.
Procedure No. HP-10. 10, "Efficiency Calibration of Low Background Alpha/Beta Counter" (Rev.
0, effective December 27, 1985),
was available and contained a requirement for annual calibration.
Two -other proced-ures HP-10.5 and HP-10.9 were found to contain a calibration frequency requirement.
Based on these findings, this item is closed.
3.8 Closed Noncom 1 iance Item 85-18-04:
The 1984 Annual Radiological Environmental Operating Report AREOR) was submitted with LLDs provided in Table XII of the report which were the LLDs of previous report years.
The LLDs reported in the 1984 annual report did not represent the actual LLD data for 1984.
During NRC Inspection No. 86-10, the inspector reviewed the licensee's corrective actions.
A corrected copy of Table XII of the 1984 AREOR was attached to the licensee's written response dated Novembe~
15, 1985 to the NRC.
This corrected table was reported to contain data based on 1984 background sample spectra.
In addition, in their written response, the licensee stated that the 1985 report would be formulated using observed LLD data.
Based on this licensee response, this item is closed.
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Closed Noncom l iance Item 85-18-05 The LLD of 1 picocurie per liter was not achieved for I-131'for all
'ater sample analyses for the reporting period from January 1984 to
'he time of the inspection.
The LLD achieved ranged between 8 and 110 picocuries per liter.
During NRC Inspection No. 86-10, the licen-see's corrective action was reviewed.
The licensee had stated that a
new procedure designed to meet the 1 pico'curie per liter LLD for Iodine-131 in water was placed in effect on September 23, 1985.
The inspector reviewed Procedure No..CE-4.3,
"Analysis for Low Level I'odine-131 in Water" (Rev. 0; effective September 23, 1985).
This procedure involves solvent extraction and precipitation of the iodine.
This procedure, in its "precautions and limit values" section, states that the Technical Specification requirement for the LLD is 1 pico-curie per liter in environmental water samples.
Based on these corrective actions, this item is closed.
3.10 Closed Noncom liance Item 85-18-06
The water sample at the Russell Station has not been composited in accordance with the requirements of the Technical Specifications.
From January 1984 to'the date of
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the inspection, composite water samples were collected by taking a
daily aliquot rather than collecting aliquots at intervals not exceed-ing two hours.
During NRC Inspection No. 86-10, the licensee's cor-rective actions were reviewed against those specified in their response
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dated November 15, 1985.
In this response, the licensee stated that an auto-sampler was installed at Russell Station on September 23, 1985.
The inspector reviewed Procedure No. CE-4.2, "Collection and Gross Activity Determination on Environmental Water Samples" (Rev. 5; effective march 6, 1986).
This procedure covers the use of the auto sampler at Russell Station.
Based on these corrective actions, this item is closed.
3. 11 Closed Followu Item 85-22-01
The licensee committed to update the gamma-ray abundances for I-135 and to review the entire radio-
'nuclide 1'ibrary to"determine" whether additional'pdating was warranted.
During NRC Inspection No. 86-10, the licensee stated that the radio-nuclide library had been changed for the gamma spectroscopy systems and that one data source was used which contained updated gamma-ray abundances for I-135.
A procedure change notice which indicated that this revision had been made was reviewed by the inspector.
Based on these findings, this item is closed.
3.12 Closed Fol 1owu Item 85-22-02:
Procedures A-103.10 and A-103.11 did not accurately reflect the requirements of ANSI N18. 1.
During NRC Inspection No. 86-10, the inspector determined that Procedure A-103. 10 is applicable to radiation protection and radiation chem-istry technicians.
The licensee indicated that a requirements for one year of technical training was not added to Procedure A-103. 10 since the standard
"recommends" rather than "requires" one year of technical craining.
It was determined that the licensee at this time is actively working towards certification of its training program for the above-mentioned technicians.
A Nuclear Training Manual has been developed and reflects the requirements of the ANSI standard for a technician training program.
Based on this.finding, this item is closed.
3.13 Closed Fol l owu Item 85-22-03:
The licensee indicated that revi s-ions would be made to the procedural review system to ensure timely signoff of all new procedures by technicians.
During NRC Inspection No. 86-10, a
new "procedure/document acknowledgement" form with a routing date, a return date provision, and a requirement for initialing
. as acknowledgement was in use.
This review system will be admini s-tered by the Training Department.
Based on this finding, this item is closed.
3.14 Closed Followu Item 85-22-04:
The licensee indicated that addi-tional technical expertise would be brought in prior to the perform-ance of the 1985 Health Physics and Chemi.stry Audit.
During NRC Inspection No. 86-10, the inspector reviewed the corporate audit of Health Physics Chemistry and Environmental Controls (Report No.
85-59).
The audit team consisted of a company auditor, the corporate health physicist and a contracted HP/auditor.
This audit appeared to be adequate in scope and depth.
Based on these findings, this item is close II l
3. 15 Closed Followu Item 85-25-02
The licensee stated that a
re-,
placement training program for two inexperienced instructors would be developed in accordance with the Technical Specification for faci 1-ity staff.
During NRC Inspection No. 86-10, the inspector determined that the licensee has reviewed the instructor training and certifica-tion program.
The program has been expanded to incorporate training and has been formalized in the Nuclear Training Manual.
The for-malized program is being used for all training staff instructors.
Based on these findings, this item is closed.
3.16 Closed Fol1owu Item 85-25-03:
The licensee stated that their
. safety analysis for the onsite storage facility would be revised by March 1986 to incorporate Generic Letter 81-38 concerns which were not previously addressed in their safety analysis.
During NRC Inspec-tion No. 86-10, the inspector reviewed the=following:
(1) "Design Criteria, Ginna Station, Radwaste Storage Facility (EWR 3057, Rev.
1, September 11, 1981)"; (2) "Safety Analysis, Ginna Station, Radwaste Storage Facility (EWR 5057, Rev.
1, September 11, 1981)";
and an inter-office correspondence memo dated March 7, 1986 and titled
"Generic Letter 81-38, Storage of Low Level Radioactive Wastes at Power Plant Sites.
This memo appeared to address the generic letter concerns which were not covered by the other two documents.
Based on
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this review, this item is closed.
4.0 Or anization and Mana ement Control The licensee's organization and management control of the radiation protection function was reviewed against criteria contained in:
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Ginna Station Technical Specification 6.0, "Administrative Controls"
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Ginna Station Procedure A-l, "Radiation Control Manual"
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Ginna Station Procedure A-201, "Administrative and Engineering Staff Responsibilities" The licensee's performance relative to these criteria was reviewed by discussions with licensee personnel and by inspection of the following:
Current Ginna Station Health Physics and Chemistry Organization chart Records of health physics inspection tours by HP supervision on January 20-23, 1986 and on February 16, 1986 Audit Finding Corrective Action Reports (AFCARs) for Corporate Audits 85-59 and 86-09 Audit planning, checklists, and reports for Corporate Audits 85-59 and 86-09
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Some of the titles and responsibilities of the health physicists had been changed several months ago
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These changes had not yet been reflected in the licensee Procedure A-201 and in the updated FSAR.
Several new position descriptions had not yet been documented.
The licensee indicated that the FSAR would be updated at the required time.
However, several revised position descriptions are not scheduled to be available for several more months.
One health physicist position has turned over recently.
This has resulted in the overall reactor HP experience level in the Health Physics group to decline and in a temporary understaffed condition to exist while the new individual becomes knowledgeable of the site-specific organiza-tion, conduct of operations, radiation protection program, and procedures.
Communication between the health physics group and plant management remains effective.
HP participates in the weekly Managing Group meetings, the daily Morning Priority Action Required (MDPAR) meetings, and the ALARA committee meetings.
Mechanisms used by the licensee to identify and correct weaknesses are:
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Corporate Audits
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Meekly inspections (Procedure No. A-54.6, "Health Physics Tour" )
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Controlled Area Incident Log (CAIL)
The licensee uses a corrective action tracking system to,.follow up on significant deficiencies found by the weekly inspections.
The licensee stated that the CAIL is reviewed periodically by health physics supervision and followup action is taken on incidents as appropriate.
,This log is kept in an office near the main radiological control point and entries can be made by any member of the health physics group.
A weakness of the CAIL is'that it is not proceduralized and that it does not formally provide for incidents to be tracked for corrective action on a timely basis.
Addition-ally, these mechanisms for identifying and correcting weaknesses are not used for trending incidents in any formalized way.
Audit planning, checklists, reports and AFCARs for Corporate Audits 85-59 and 86-09 were reviewed by the inspector.
The status of. corrective actions on audit findings was also reviewed.
These audits covered the areas of health physics, chemistry and environmental controls.
The licensee stated that the level of effort and the technical depth of these audits had been upgraded from that expended in previous audits.
This upgrade was at,least partly in response to recent NRC inspections findings.
The inspector noted that the audit checklists had been and were still being revised to provide more in-depth technical review.
Additionally, on Audit 85-59, the audit team included two individuals with health physics expertise.
These two audits resulted in numerous findings, several of which were apparent violations of the licensee's technical specifications.
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and recorded licensee responses and actions on the latter findings were reviewed against the criteria of 10 CFR 2, Appendix C, V.A., and these criteria for self-identification and correction of problems appear to have been met.
5.0 Trainin and uglification of Personnel The adequacy and effectiveness of the licensee's training program was reviewed against criteria contained in:
CFR 19.12, "Instruction to Workers"
CFR 20. 103,
"Exposure of Individuals to Concentrations of Radio-active Materials in Air in Restricted Areas" Regulatory Guide 8.27, "Radiation Protection Training for Personnel at Light Water Cooled Nuclear Power Plants" Regulatory Guide 8.29, "Instruction Concerning Risks from Occupational Radiation Exposure" ANSI N18. 1 (1971) "Selection and Training of Nuclear Power Plant Personnel Station Procedures A103.2, General Employee Training
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A103. 3, Temporary Emp 1 oyee Tra ini ng
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A103.10, Radiation Protection Technician Training and Responsi-bilityy Limits
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TR-4.2, Instructor gualification
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TR-4.3, Instructor Certification
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HP12.2, Medical Check, Fitting and Training of Personnel Using Respirators The licensee's performance relative to these criteria was determined by:
Review of lesson plans Interviews with randomly selected workers Review of instructor qualifications and experience Tour of various training facilities
The course outlines for radiation workers and technicians were reviewed and found to cover areas of general health physics, site specific factors, and Federal Regulations, adequately.
Randomly chosen radia-tion workers in the plant were interviewed and found to retain adequate knowledge of these subjects.
Worker training includes a practical demonstration of proper technique when entering and exiting controlled areas, dressing and undressing, use of survey maps, interpretation of station signs and barriers, use of step off pads and friskers.
This training is provided for each individual involved in the training program to permit familiarization with a typical work place and the work practices that are expected.
Instructors use formal lesson plans which include audio-visual aids as well as direct instruction.
The instructors were verified to be sufficiently qualified by previous academic and occupational experi-ences, and by participating in continuing teacher. training programs.
The instructor certification plan appears to'be of recent origin and suitable to the licensee's needs.
These needs include minimum qualif-ication course work for new instructors, and course work necessary for existing instructors to teach new subjects.,
A random sampling of procedures taken from the newly assembled and updated training manual were reviewed and found to be adequate.
These procedures were updated, for the purpose of obtaining INPO accreditations in the area of training.
The inspector determined the new traiaing procedures were an improvement over the previously existing procedures.
The respiratory protection training program included the regulatory requirements, however, the inspector noted the lecture outline for respiratory training to be minimal when compared with similar outlines in the nuclear industry.
The inspector was informed that the program including the outline is currently undergoing a complete rewrite to improve course content.
A tour of the training facility was performed.
The facility was small but was found to include the necessary equipment, classrooms, and study areas.
Within the scope of this review, no violations were identified.
6.0 Control of Radioactive Material and Contamination Surve s and Monitorin The adequacy and effectiveness of the licensee's programs in these areas were reviewed against criteria contained in:
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CFR 20, "Standards for Pr'otection Against Radiation"
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Station Procedures
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HP-5.1, Area Radiation Surveys
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HP-5.2, Posting of Radiation Areas and Container Labeling
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HP-6. 1, Contamination Surveys
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HP-6', Posting of Contaminated and Airborne Areas The evaluation of the licensee's performance in this area was based on:
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Observations by the inspectors;
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Performance of independent radiation surveys by the inspector;
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Reviews of documentation; and,
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Discussions with cognizant station personnel.
During the tour of the plant, the use of barriers and the posting of radiation, contamination and airborne areas were found to be adequate.
The orderliness oi'he plant was observed to b'e acceptable.
During the tour, work practices of workers encountered was monitored and found to be acceptable.
V Surveys for the station were reviewed and compared with station pro-cedures.
The surveys were well organized, documented, and readily available.
The health physics personnel were able to provide surveys of various work areas quickly.
The surveys were neat and were reviewed by management in a timely manner.
Frequencies and time.
constraints for surveys required by procedures were examined and found to be acceptable.
Within the scope of this review, no violations were identified.
l1 7.0 Exit Interview The'nspectors met with the personnel denoted in Section 1.0 at the con-clusion of the inspection on July 18, 1986.
The'cope and findings of the inspection were discussed at that tim tl Cl t
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