IR 05000244/1988020
| ML17251A327 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/12/1988 |
| From: | Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A326 | List: |
| References | |
| 50-244-88-20, NUDOCS 8810210218 | |
| Download: ML17251A327 (18) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244 88-20 Docket No.
50-244 License No.
DPR-18 Priority Category Li,censee:
Rochester Gas and Electric Cor oration as venue oc es er ew or Facility Name:
Ginna Nuclear Power Plant Inspection At:
Ontario New York Inspection Conducted:
Se tember 19-23 1988 Inspector:
ea oc
,
a ia ion pecia is a
e Approved by:
an a y, ie
,
aci >>es a ia ion Protection Section
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e Ins ection Summar:
Ins ection conducted on Se tember 19-23 1988 Re ort No.
Areas Ins ected:
Routine, unannounced inspection to review the status of previous y i en ified items in the Radiological Controls area.
The inspector also reviewed the licensee's ALARA program.
Results:
No violations were identified.
Seven open items identified during prev>ous Radiation Protection inspections were c'losed out.
Weaknesses were identified in the areas of worker training on the use of survey meters (section 3.6)
and documentation of job-coverage surveys (section 3. 10).
8810210 peD00244 8 881014 PDF'DOC PDC
1.0 Persons Contacted
- D.Filkins
- M.Goodman
- N.Kiedrowski
- R.Marchionda
- F.Mis
- T.Schuler
- S.Spector
- J.Supina DETAILS Manager, Health Physics (HP)
and Chemistry Health Physics Foreman Training Coordinator, HP
& Chemistry Ginna Training Manager Health Physicist Operations Manager Station Superintendent ALARA Coordinator/Dosimetry Supervisor 2.0 3.0 3.1
- Attended the exit interview on 9/23/88.
Other licensee personnel were also contacted during the course of this inspection.
~Pur ese The purpose of this routine, unannounced inspection was to review the status'of follow-up items identified during previous inspections of the licensee's Radiological Controls program.
Implementation of the ALARA program was also reviewed during this inspection.
Status of Previousl Identified Items (Closed)
Follow-up Item (244/85-08-01):
Demonstrate that a representative reactor coolant sample can be obtained via the Post-Accident Sampling System (PASS) in low pressure conditions.
In February, 1986, the licensee performed a study to evaluate sample flow availability to the PASS panel during low pressure conditions in the RCS.
Sample flowrates were measured as the reactor coolant pumps were shut down and RCS pressure dropped to a low of approximately 17 psi.
The licensee verified adequate sample flowrate was available to obtain an RCS sample during these conditions.
The inspector reviewed the results of this study and had no further questions in this area.
This item is closed.
3.2 (Closed)
Follow-up Item (244/85-08-06):
Empirical checks should be performed to verify calculated sensitivities of main steam line monitors.
Calculations and assumptions used to relate steam line monitor response to post-accident gas concentrations were made by the licensee's contractor
3.3 3.4
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Technology for Energy Corporation)
and are given in TEC Report No.-81-020, titled "Calculation of Dose to Activity Conversion Curves for Determination of Activity Concentrations Within Steam Lines A88 of Ginna Nuclear Station."
This report was reviewed during a previous 0737 inspection (NRC Inspection No. 244/85-08)
and dur ing the current inspection.
The inspector determined the report's stated dose to activity conversion curves are adequate and further studies or empirical checks by the licensee are not warranted based on ALARA considerations.
This item is closed.
(Closed)
Follow-up Item (244/85-08-10):
Licensee to demonstrate post-accident particulate, iodine, and noble gas effluent samples can be obtained within GDC-19 limits of 5 rems to the whole body, 75 rems to the extremities.
During NRC Inspection No. 244/87-05 the inspector reviewed licensee calculations of anticipated dose to emergency workers collecting post-accident effluent samples.
Estimated doses were within the above GDC-19 limits.
The inspector noted, however, that the controlling procedure (PC-23.6,
"SPING 4 Iodine and Particulate Sample Change and Grab Sample for Plant Vent or Containment Vent During Emergency Conditions" ) had not been field-tested by the licensee.
The inspector also noted some confusing steps in the procedure.
This item was consequently left open during inspection 244/87-05 pending additional licensee action.
During the 1988 semiannual health physics drill the licensee performed a
SPING 4 iodine and particulate filter plant vent sample changeout and retrieval under simulated accident conditions.
The inspector reviewed drill comments and noted the samples were collected without problem and that procedure PC-23.6 was adequately field-tested.
Inspector review of PC 23.6 identified several areas for additional procedural improvements.
The licensee subsequently generated a Procedure Change Notice (PCN) to further upgrade the procedure.
The PCN was approved September 29, 1988.
This item is closed.
(Open) Follow-up Item (244/85-08-11):
Determine line losses through gaseous effluent sampling lines to ensure representative sampling.
The licensee has budgeted funds for a study, to be performed by Science Applications International Corporation, to evaluate potential particulate and iodine losses during gaseous effluent sampling.
The licensee stated the study should be initiated within the next few months.
This item remains open pending review of the results of the study and incorporation of generated factors, etc. into the applicable procedure.5 3.6 (Closed)
Follow-up Item (244/85-08-15):
Licensee to replace the sample counting system in their back-up analysis lab.
The licensee's back-up sample analysis facility is the Environmental Lab, which is located in a trailer on site.
The Environmental Lab is typically used to count routine environmental samples.
The licensee has recently replaced the old counting system in the Environmental Lab with a new ND-66 counting system.
Procedures for equipment operation have been written and approved and system training was being conducted during the week of the inspection.
The inspector verified the backup ND-66 system features e
ost-accident counting geometries and the licensee's post-accident counting ibr ary.
This item is closed.
Closed)
Follow-up Item (244/85-25-01):
Review licensee's updated General mployee Training (GET).
The licensee periodically reviews the radiation protection section of GET.
The inspector reviewed the following lesson plans currently associated with general employee radiation worker training:
-LP GRC01C 4/87
, "Health Physics Orientation",
-LP GRC06C 1/88
, "Health Physics Requalification",
-LP GRC04C 7/87
, "Health Physics Review".
Incoming employees (contractor or permanent)
with no previous radiation protection training receive the HP Orientation course.
Contractor and RG&E
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ersonnel with previous, recent radiation protection training receive the P Requalification and HP Review training, respectively.
All levels of radiation worker training include a practical factors segment.
This was noted as a licensee strength.
The inspector reviewed the above lesson plans and noted them to be satisfactory, with the following exception.
The licensee periodically rovides radiation survey meters to experienced RG&E personnel working in igh Radiation Areas, to fulfillTS 6. 13 requirements.
The inspector noted, however, that formal instruction in meter use is not included in the two lesson plans delivered to RG&E employees, i.e.
A discussion of meter use is provided in the HP Requalification lesson plan; however this is not provided to RG&E employees.
The licensee indicated that meter use had been discussed in previous RG&E radiation protection lesson plans but had been inadvertently excluded from the current lesson plans.
The licensee stated that specific training for meter use would be developed and incorporated into the applicable lesson plan for experienced RG&E personnel.
This will be reviewed during a future inspection as part of the routine review of radiation worker trainin.7 3.8 (Closed)
Unresolved Item (244/87-19-02):
Licensee to correct calculation of extremity dose on NRC Form 5s.
During NRC Inspection 244/87-19 the inspector identified that the licensee was calculating quarterly worker extremity dose by adding monitored extremity dose (monitored with ring badges, etc.) to whole body deep dose.
Instructions for NRC Form 5 indicate that doses recorded as dose to the extremities should include the dose delivered through a tissue equivalent absorber with a thickness of 7 mg/sq.
cm. (i.e., shallow dose).
Licensee corrective actions to the above unresolved item included revising procedure HP 1.2, "External Exposure Limits", to include statements that extremity exposure limits apply to the skin of the extremities.
The licensee also briefed dosimetry processing personnel as to the correct methodology for calculating and recording extremity dose.
The licensee also performed an extensive review of previous extremity exposure records to identify if extremity exposures in excess of federal limits had occurred and had gone unidentified.
Inspector review of this report verified no overexposures had occurred.
The inspector noted a weakness in the above corrective actions, in that the inappropriate procedure was revised by the licensee to correct the above concern.
Procedure HP 1.2 describes station administrative limits and is not used by the dosimetry processors to calculate and record doses.
The licensee subsequently generated a
PCN to revise procedure HP 1.3, "External Exposure Records",
to reflect the correct dose calculation methodology.
This procedure is used by the dosimetry processors to complete Form Ss.
This PCN was approved September 29, 1988.
The licensee also stated that a
new HP computer system (the RDNS system)
would shortly be operational and would correctly calculate extremity doses automatically.
Thi s itern i s cl osed.
(Closed)
Follow-up Item (244/87-19-04):
Discrepancy among drawer, recorder, and computer readings during calibration for area radiatson monitors.
During NRC Inspection 244/87-19 the inspector identified a discrepancy among the drawer, recorder, and computer readouts for certain area monitors during calibration.
Specifically, the drawer reading would correspond to the calibration dose rate; however the recorder and computer readout would read two to four times the drawer reading.
Subsequent to the above inspection, the licensee began a program to upgrade Rl-R9 by changing out the monitor preamplifiers.
Three of the monitors have been upgraded so far.
The inspector reviewed 1988 calibration data for area radiation monitors Rl-R9 and noted that the problem of elevated recorder and computer readout readings persists for two monitors, Rl and R5.
Drawer readings for all the monitors accurately reflected the calibration dose rate.
The inspector verified annunciator alarms in the
control room are signaled by the drawer readings, rather than recorder or computer readouts.
The inspector concluded the open item in this area could be closed, based on the following:
- a "trouble card" is still open on the monitors and the licensee has a plan to continue monitor upgrade,
- drawer readings for all monitors are accurate and control room alarms are based on monitor drawer readings.
This item is closed.
3.9 Open) Violation (244/88-03-01):
Failure to control High Radiation Area HRA) entry in accordance with Technical Specification 6. 13 requirements.
The inspector reviewed licensee actions against corrective actions outlined in their response to the above violation.
Short-term corrective actions have been completed and include generating a Radiological Incident Report and briefing the HP section regarding the violation.
Several corrective actions included in the licensee's response have not been completed; these include the following:
- development of a radiological posting control procedure,
- including discussion of the violation in contractor HP technician training,
- revising the Special Work Permit (SWP) format to highlight HRA controls to be utilized,
- designation of a "lead HP technician" for both the Containment and Auxiliary buildings during the 1989 outage.
This item will remain open pending implementation of the above actions.
The licensee also indicated additional steps are being taken to improve the level of contractor HP technician coverage during the 1989 outage.
These include bringing in more contractor technicians than during the 1988 outage and bidding For ANSI 3.1 vs.
ANSI 18. I technicians (i.e.,
3 years minimum vs.
2 years minimum of experience).
Implementation of these uprgrades will be reviewed during the 1989 outage.
3. 10 (Open) Violation (244/88-03-02): Multiple examples of a failure to follow procedures, including: I) failure to follow work permit procedure by providing radiological survey data on Special Work Permits(SWPs),
and 2)
failure to follow WBC gC procedure by investigating out of control daily source check result Initial licensee corrective action as outlined in their response to the above violation has been completed.
Specifically, a meeting was held with the Health Physics section to discuss the above violation and related concerns.
A short training session on the importance of laboratory gC and the use of control charts was also presented.
The inspector reviewed meeting minutes and summary of the gC training and determined the scope was appropriate.
The licensee has also revised procedure A-54.6, "Health Physics Tour", to require HP supervisors to review laboratory gC control charts as part of their routine area tours.
Additional corrective actions are being planned by the licensee.
A full-time staff position has been created for an individual who will oversee laboratory and instrument gC.
The licensee also plans to revise the HP work permit procedure to require the attachment of a radiological survey to the work permit at the job site.
This change is intended to be-implemeted with the activation of the RDHS system.
The inspector reviewed licensee performance in the area of laboratory gC and radiological surveys during the current inspection.
The inspector noted reviewed gC charts were being updated and radiological survey information was included on all reviewed SWPs.
The following deficiencies were noted, however.
o Several source check results were mis-plotted on the control chart for the Geli system in the Environmental Lab.
o Documentation of a survey made to support a containment entry during the week of the inspection was made by writing area dose rates on the SWP after the entry was complete.
Consequently, information typically required on survey documentation (signature, instrument type and serial number, time) was not included.
This was noted to be a poor practice.
o No direction was given in the licensee's work permit or radiological survey procedures (HP-4.3 and HP-5. 1, respectively)
concerning the performance, appropriate scope, or documentation of job-coverage type surveys.
o Several of the pre-printed survey forms used by the licensee for recording routine survey information were of poor quality and legibility.
The licensee indicated the above concerns would be addressed.
This item remains open pending the following actions:
- hirinq of additional personnel to oversee laboratory and instrument gC functions,
- revision of procedures to require a survey attachment form with the work
permit at the job-site,
- revision of procedures to improve job-coverage survey documentation,
- upgrade to routine pre-printed survey forms.
4.0 ALARA The inspector reviewed the implementation of the ALARA program by the following methods:
- discussion with cognizant personnel, including the ALARA Coordinator,
- review of 1988 exposure data and selected post-outage work reviews,
- review of selected procedures.
Within the scope of the above review, no violations were identified.
The following areas of strong peformance were noted:
- 1988 exposure is currently approximately 244 man-rem, with a projected annual exposure of 260 man-rem.
The station 1988 exposure estimate was 297 man-rem.
1988 work scope included a refueling outage.
- Review of survey records indicate significant source term and area dose rates in the lower level of containment.
The licensee is evaluating various source term reduction techniques (RHX replacement, primary system partial or full decon) to reduce area dose rates.
- The ALARA exposure goal-setting process for routine, recurring work operations was well documented and controlled.
Goals were challenging as compared to previous work history, yet wor k was completed close to the estimate.
The following areas for improved licensee performance were noted during the above review:
- The ALARA exposure goal-setting process for non-routine work evolutions
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i.e.,
one time modifications) requires additional attention.
Review of 988 actual versus estimated exposure for various modifications identified goals were routinely high and consequently not challenging.
The licensee indicated this was chiefly due to inflated man-hour estimates from the work groups and additional effort would be taken to obtain realistic man-hour estimates.
- The licensee does not use ALARA area signs, ALARA incentive signs, etc.,
as typically used at other plant t
The licensee is currently purchasing a large quantity of new radiological signs to upgrade radiological posting practices.
The licensee indicated ALARA Area signs are being purchased and will be implemented.
- The responsibility for the performance of in-field ALARA reviews of ongoing work activities is not clearly assigned to a designated individual.
The ALARA Coordinator is also the Dosimetry Supervisor and does not conduct pre-job briefings, tour work areas, and review in-field implementation of ALARA reviews.
No HP technician assistance is assigned to the ALARA area during outages, a practice common at other sites.
The licensee indicated they would evaluate the option of providing a
specific individual to perform in-field ALARA functions to support the next outage.
Licensee response to the above items will be reviewed during future inspections of the ALARA program.
5.0
~Eit N ti The inspector met with licensee representatives, denoted in Section 1.0 of the report, on September 23, 1988.
The inspector summarized the purpose of, scope and findings of the inspection.