IR 05000244/1989023
| ML17250A998 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/06/1989 |
| From: | Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17250A997 | List: |
| References | |
| 50-244-89-23, NUDOCS 8909220125 | |
| Download: ML17250A998 (16) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244 89-23 Docket No.
50-244 License No.
DPR-18 Priority Category Licensee:
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:
Au ust 7-11 1989 Inspector:
C onne
,
a ia ion pecia ss p-g/- g'+
a e
/
Approved by:
ascia
,
>e
,
ac> >>es a ia ion Protection Section a
e Inspection Summary:
Inspection conducted on August 7-11, 1989 (Report No.
50-244/89-23).
Areas Ins ected:
Routine, unannounced inspecti'on of the licensee's Radiological on ro s
rogram.
Areas reviewed include: corrective actions on previously identified items, audits and appraisals, radiation protection training of licensee personnel, external exposure controls, internal exposure controls, and ALARA.
Results:
No violations were identifie.0 Persons Contacted
- D. Filkins W.
Goodman
- A. Herman N. Kiedrowski
- F. His
- B. Quinn
- Y. Selbig S. Spector
- J. St.Hartin
- S. Warren
- R. Watts
- J. Widay DETAILS Hanager, HP and Chemistry Health Physics Foreman
'ealth Physicist Training Coordinator, HP It Chemistry Health Physicist Corporate Health Physicist HP/Chem QC Specialist
.Station Superintendent Corrective Action Coordinator Health Physicist Director, Corp. Radiation Protection Superintendent, Ginna Production
- Attended the exit meeting on August 11, 1989.
Other licensee personnel were also contacted during the course of this
. inspection.
2.0
~Per ese The purpose of this routine, unannounced inspection was to review the following elements of the licensee's radiation protection program:
- the status of previously identified items,
- audits and appraisals,
- radiation protection training of licensee personnel,
- external exposure control,
- internal exposure control,
- ALARA.
3.0 Status of Previousl Identified Items 3. 1 (Closed) Violation (244/88-03-01):Failure to control a High Radiation Area (HRA) entry.
The inspector reviewed the licensee's corrective actions against corrective actions outlined in their response to the above violation dated April 28, 1988, The inspector verified that the following long term corrective actions had been satisfactorily completed:
- requiring daily tours by the Health Physics Technicians (HPTs)
and weekly tours by the Health Physicists in order to ensure that areas have the proper radiological postings,
- including a discussion of the violation in contractor HPT training,
- revising the Special Work Permit (SWP) format to highlight HRA controls to be utilized,
- designating lead HPTs during the refueling outage.
This item is closed.-
3;2 4.0 I'Closed)
Violation (244/88-03-02):Failure to follow procedures.
The inspector reviewed the licensee's corrective actions against corrective actions outlined in their response to the above violation dated April 28, 1988.
The inspector verified that the long term corrective actions as specified in their response letter had been satisfactorily completed.
This item is closed.
Audits and A
raisals The inspector reviewed the licensee's quality assur ance report,
"Audit of Ginna Station Outage-Activities",'dated July 6, 1989, to assess the scope.
of the licensee's audit of HP activities during the last refueling outage.
The audit was performed by technically qualified personnel and the audit report reflected an appropriate scope of review.
The licensee performs three annual routine quality assurance audits in the HP area.
Inspector review of these audits also indicated an appropriate scope of review by qualified individuals.
The inspector reviewed several Radiological Incident Reports'RIRs)
to assess whether adequate management review and appropriate corrective actions were completed.
Several of the RIRs reviewed were not signed by the appropriate manager or did not list any corrective actions as being completed.
The inspector discussed these discrepancies with the HP and Chemistry Manager and determined that the RIRs had been reviewed by licensee management as required and that appropriate corrective actions had taken place.
The inspector stated that the documentation of the review and resolution of RIRs was an area that needed im~rovement.
The licensee supplied the inspector with Procedure HP-3.0
'Radiological Incident Report" which had been revised in Hay 1989.
This revision incorporated a formal RIR tracking system with an individual designated as a Corrective Action
.
Coordinator who is responsible for ensuring that'RIRs are satisfactorily completed.
The effectiveness of this system will be reviewed during a
future inspection.
5.0 Trainin and ual ificat ions The inspector reviewed the lesson plans for the licensee's'"Radiological Protection General Employee Training"..
By examining the training records of randomly-selected individuals, the inspector verified that plant personnel had received annual training in the area of radiation protection.
No discrepancies were noted in this area.
The inspector reviewed the licensee's training program for ensuring that individuals who are given radiation monitoring instruments are trained in their proper use.
Operators and Auxiliary Operators are issued radiation monitoring instruments for entries into High Radiation Areas and Locked High Radiation Areas.
The following problems were noted in the training program:
- The training consisted of a single sign-off which could be signed by any ualified Operator without any input from the HP or training departments.
he licensee could not verify that the training included the fotlowing information:
precautions to take while using the instruments, instrument limitations, required preoperational checks of the instruments, and actions to take if the instrument alarms or goes off scale.
- The training did not address the radiation monitoring instrument normally issued to Operators and Auxiliary Operators (i.e. the Alnor Rad-85).
The inspector determined, by discussions with HP personnel, that prior to being issued an instrument operators were informally shown how to properly operate the instrument.
The licensee provided the inspector with a copy of a new training lesson plan entitled "Self Monitoring Using the Alnor Rad-85, the Victoreen 450-B, and the (Eberline)
RO-2A Ion Chamber" which had been approved August 8, 1989. This lesson plan addressed the proper use of the radiation monitoring instruments which Operators and Auxiliary Operators are allowed to use.
At the time of the inspection no Operators had yet received this training.
The licensee stated that all of the Operators and Auxiliary Operators would undergo training, conducted by the training department, during the next six week training rotation. This item will be reviewed during a future inspection, External Ex osure Controls The licensee's program for external exposure control was reviewed with respect to criteria contained in 10 CFR 20 "Standards for Protection Against Radiation".
Performance relative to these criteria was determined by review of posting areas and labeling components for radiological protection purposes, direct observation of work in progress, review of Special Work Permits (SWPs)
and Radiation Work Permits (RWPs),
and review of dosimetry records.
Within the scope of this review no violations were observed.
The inspector observed several job activities related to the repair work which was being done on a control rod position indicator coil, located inside containment, and also various decontamination activities inside the Auxiliary Building. The inspector verified that dosimetry was worn properly and that the SWPs were posted at the job site and the attached survey record form, which is used to document the intermittent HP job coverage surveys, were completed at the frequency specified on the SWP.
Recently the licensee initiated a practice of attaching labels on portable radiation monitoring instruments.
These labels are marked daily indicating that they had been satisfactorily response checked.
Under the prior system, an individual had to verify that an instrument had been response checked on that day by examining a logbook which is kept in the radiochemistry lab.
The inspector considered this to be an improvement in that individuals can now readily verify that instruments have had the required response check prior to us.0 During a tour of the site the inspector noted that the door leading into the work area of a contractor's decontamination trailer was propped open.
With the door propped open, postings on the door were not visible to warn individuals of any radiological hazard in the area.
Upon closing the door, it was found that the area was posted with a High Radiation Area posting and a Radioactive Haterials posting.
The licensee stated that the area had been posted as a High Radiation Area while the trailer was used to decontaminate radioactive equipment. After the equipment had been removed from the trailer the High Radiation Area posting was not removed even though the area no longer was a High Radiation Area. Inspector review of the most recent radiological'urvey of the trailer confirmed that the area did not need to be posted as a High Radiation Area or a Radiation Area.
The inspector noted that the radiological survey which was posted in the trailer was over five weeks old. Subsequently the licensee updated the survey of the trailer with a survey which had been completed the previous week but had not been posted in the trailer.
The inspector stated that mor'e attention needs to be placed on updating surveys which are posted in the field, updating postings to reflect the radiological hazard, and ensuring that postings are properly positioned.
The licensee stated that, prior to this finding, outside areas of the plant were not included in the daily HPT tours, which are conducted to ensure that areas are properly posted.
The licensee stated that in the future the HPT will tour the outside areas of the plant when the daily HPT tours are performed.
Internal Ex osure Controls The licensee's program for internal exposure control was reviewed with respect to criteria contained in 10 CFR 20 "Standards for Protection Against Radiation".
Performance relative to these criteria was determined by review of posting of Airborne Radioactivity Areas, review of HPC-hour tracking records, and review of the quality control system used for the air sample, smear, and whole body counters.
Within the scope of this review no violations were observed.
The licensee established an NPC value of 7.73E-ll uCi/ml for airborne radioactivity concentrations of alpha emitting radionuclides.
This value was based on an October 1986 laboratory analysis of the solubility and alpha isotopic composition of samples taken inside containment.
The licensee stated that the alpha HPC value is evaluated annually when waste streams are analyzed for 10 CFR Part 61 requirements.
The licensee could not provide the inspector with any documentation of any re-evaluation completed after the 1986 study.
The inspector verified, using the January 1989 scaling factors results, that the NPC value for alpha was appropriate.
The inspector stated that evaluations such as this need to be documented.
The licensee stated that in the future they would document these evaluation '
The inspector reviewed control charts for the smear, air-sample, and whole body counters.
The licensee recently made an improvement in its pro~ram by
'mplementing a "Health Physics and Chemistry guality Control Review procedure.
This procedure requires that a Laboratory guality Control Specialist weekly review the control charts for the counting equipment.
The inspector noted that several of the control charts showed that the counting system exhibited a negative bias over -a period of five to six weeks.
The scope of the licensqe's review of the. control charts was considered good, but their follow-up of the review seemed slow.
The Laboratory guality Control Specialist documented, on several of the weekly quality control reviews, that the system was showing a bias and that the cognizant supervisor had been notified. However, at the time of the inspection, no action had been made by the cognizant supervisor to address this finding.
The licensee stated that they will change the guality Control Review Form to require the cognizant supervisor respond to quality control findings.
The inspector noted that the licensee was not performing a response check specifically for alpha counting.
The licensee uses an alpha/beta proportional counter for determining gross alpha and gross beta levels for smear and airborne radioactivity surveys.
The licensee performs a daily beta response check of the counting system, at the operating voltage for beta'ounting.
The licensee, stated that the operating voltage was the only parameter changed for alpha counting and that a satisfactory beta response check was adequate to ensure that the 'system was operating properly.
The inspector stated that, pnor -to counting for alpha, the instrument should be source checked at. the operating voltage used during alpha counting and with a standard emitting the same type of radiation being counted, i.e an alpha source.
The licensee stated that in the future they would perform a
daily alpha source check.
The inspector noted that the licensee allowed individuals to eat and drink in the counting room and in the area where smears and air samples are counted.
The inspector stated that this was a poor health physics practice in that it increases the potential of having an individual accidentally ingest contaminated material.
The licensee was responsive and posted signs prohibiting eating and drinking in the count room and in the area where smears and air samples are counted.
The inspector also noted that the licensee allowed eating and drinking in the "clean" chemistry lab.
The inspector stated that allowing eating and drinking in a chemistry lab was also considered to be a poor safety practice.
The licensee stated that they would evaluate their policy.
ALARA During NRC inspection 50-244/89-07 the licensee stated that a thorough review of the ALARA program would be conducted and upgrades would, be made in the ALARA program.
The inspector reviewed the status of the review and upgrade of the ALARA progra A contractor ALARA Engineer is currently reviewing licensee manuals and rocedures to ensure that ALARA concerns or specifications are addressed.
he cont'ractor is also making recommendations
.for revisions to these manu'als and procedures.
The inspector noted that the numerous, technically valid, recommendations for improvements indicated that a thorough review was being conducted.
During the last refueling outage a weakness was noted in not having ALARA personnel ava'ilable to ensure that ALARA action items are implemented in the field. The licensee stated that they recently hired a contractor ALARA technician who will provide in-field ALARA review during the next refuelin'g outage.
At the time of the inspection the licensee had not completed an ALARA-outage review.
The licensee estimated that the outage exposure was 506 man-rem.
This value exceeded the ALARA goal by 60 man-rem.
The licensee stated that this was due, primarily, to unanticipated steam generator work.
This area will be reviewed during a future inspection.,
9.0
~Eit N ti The inspector met with licensee representatives, denoted in Section 1.0 of this report, on August 11, 1989.
The inspector summarized the purpose, scope and findings of the inspectio OUTSTANDING ITEHS F
W INGLE DOCKET ENTRY FORM REPORT HOURS
. l. Operations 2.
Rad-Con 3. Maintenance 4. Surveillance 5.
Emerg.
Prep.
6. Sec/Safegrds.
7. Outages 8. Training 9. Licensing 10.
gA ll. Other 12. Fire Protection/
Housekeeping Originator Reviewing Supervisor Docket Ro.
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