IR 05000244/1991026
| ML17262A661 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/19/1991 |
| From: | Lance R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17262A660 | List: |
| References | |
| 50-244-91-26, NUDOCS 9112030034 | |
| Download: ML17262A661 (17) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
Docket No.
License No.
-244 1-2 2L244 DPR-1 Licensee:
R h
r s
nd El ri nne A R
h r NwYrkl4 i n Facility Name:
Inspection At:
Inspection Conducted:
inn u I rP werPI n N
k er 2
- Novem er
1
Inspector; d"->>te R. Lance, Radiation Specialist Facilities Radia 'on Pr [ection Section tt jfv/F(
Date Approved by:
Q s W. Pasci, Chief, Facilities Radiation Protection Section, Facilities Radiation Safety and Safeguards Branch
~tt/fcr ef Date H:Th i
I i
Mi p i
fl ChlgMp<<
program on site.
Areas reviewed included status of previous findings, organization and staffing, audits, planning and preparation for the upcoming outage, training, internal exposure controls, contamination controls and control of radioactive material, and ALARA.
R~e>lt: New initiatives in the areas of training, ALARAand respiratory protection were noted.
The licensee's staff was continuing to aggressively address the problem of personnel contaminations.
Within the scope of the inspection, no violations were identified.
9112030034 911120 PDR ADOCK 05000244 Q
DETAILS 1.0P r nn
n 11Li n
P rs nn
- W. Goodman, Health Physics Technician Foreman
- A. Harhay, Health Physics and Chemistry Manager
- A. Herman, Health Physicist
- K. Lang, Health Physicist
- F. Mis, Health Physicist R. Watts, Director, Corporate, Radiation Protection
- J. Widay, Plant Manager
- A. Jones, Corrective Action Coordinator
- K. Gould, ALARALead Technician
- N. Kiedrowski, Training Coordinator for Health Physics and Chemistry
- B. Quinn, Corporate Health. Physicist 1.2 N~RP
- T. Moslak, Senior Resident Inspector E. Knutson, Resident Inspector
- Denotes attendance at the exit meeting on November 1, 1991
~
2.0 Pu e
nd oftheln i n The inspection was an unannounced inspection of the radiological protection program on site.
Areas reviewed included status of previous findings, organization and staffing, audits, planning and preparation for the upcoming outage, training, internal exposure controls, contamination controls and control of radioactive material, and ALARA.
3.0 f Previ Fin in (Closed) Unresolved Item 50-244/91-08-01: The licensee did not establish a new self-absorption correction factor for I-131 activity calculation upon installation of new counting equipmen The licensee's method for calculating the new self-absorption correction factor for I-131 for the Tennelec alpha/beta counter was reviewed and found acceptable.
The inspector also noted that the licensee recalculated all of the results since the change in equipment was made using the new self absorption correction'actor.
This item is closed.
4.0
~Ai~i The licensee utilized a Radiological Incident Report (RIR) system to report, assess, and categorize radiological incidents and to ensure accountability and supervisory awareness of incidents caused by negligence, lack of knowledge, or other causes which could have been prevented.
The inspector reviewed the only RIR that had been generated since the last inspection and determined that the licensee's corrective actions were adequate.
In an effort to improve their RIR process, the licensee recently sent a health physicist and Health Physics planner to the Institute of Nucle'ar Power Operations gNPO) facility in Atlanta, Georgia to participate in human performance evaluation system training, This training willallow the licensee to integrate root cause analysis into their RIR program.
The inspector considered this to be a good initiative.
The licensee recently implemented station procedure A-30, "Management and Implementation of Ginna Station Commitments and Action Items."
This procedure described the process for identification, tracking, managing and implementing commitments and action items via the Commitment and Action Tracking System.
The inspector determined that this was an effective means for the licensee to identify, track, and address any concerns identified by either management or outside agencies, 5.0 affin and r
ni ti n The inspector reviewed the licensee's organization chart and noted that one professional level Health Physicist position remained vacant, This position was vacant at the time of the last inspection.
At that time, the Health Physics Department had received corporate approval to initiate the employment screening process for new applicants.
The licensee was actively attempting to fillthe position.
The individual who left was responsible for internal dosimetry and instrumentation.
At the time of this inpsection, these duties were split between the remaining three Health Physicists until a replacement is hire l
The licensee was expecting a contractor ALARAtechnician to begin employment with the utilityduring November.
The ALARAtechnician's responsibilities were to include reviewing shielding packages from the last outage for shielding justification, establishing any new shielding requirements and preparing shielding packages for the upcoming outage.
The candidate for this position performed in this capacity at the station during the last outage.
6.0 Plnnin n
Pr i n Planning for the upcoming outage was progressing well. Many of the work packages had already been submitted for'ALARAreview.
The ALARAgroup was in the process of identifying the work packages that willrequire pre-job briefings.
The licensee had an effective system for notifying the Health Physics department of planned outage activities.
A member of the Health Physics staff attended monthly outage planning meetings.
As job scope for the outage is better defined, Health Physics staff expected to become involved in the planning either through assignment to a Modification Follow Group for plant modification work or through the normal ALARAreview process.
Allwork packages were, routed through the ALARAoffice, and a determination was made as to the extent of ALARAreview required.
One of the ALARAtechnicians was dedicated to preparations for steam generator work in the upcoming outage.
Approximately 70% of the ALARAreview packages for steam generator work were already prepared.
During the outage, another ALARAtechnician was scheduled to work with the steam generator group.
The responsibilities of these technicians included emphasizing the importance of mock-up training, ensuring proper dress-out procedures are understood and followed by all steam generator workers,,and ensuring proper communications between the steam generator group and the health physics technicians at the job site.
The licensee was planning to use mock-up training for personnel involved with steam generator work, steam generator insulation removal, and thermocouple work on the reactor head.
The licensee had found that the use of mock-up training for these or similar jobs resulted in substantial dose reduction in the pas.0 Trrin~in The inspector reviewed selected aspects of the licensee's training program.
Areas reviewed included the mechanism by which safety significant changes to procedures and recent industry events were relayed to plant personnel and contract technicians, contract technician training, pre-outage training and systems training for permanent health physics technicians, and training for decontamination technicians.
7.1 r
r h n n
R n In Ev n Several methods were used for communicating safety significant procedural changes and recent industry events to permanent and contractor health physics personnel.
Section meetings were held with the health physics staff to discuss recent industry events and evaluate their relevance to operations at Ginna.
Revised procedures and other significant documents were routed to all health physics personnel, both permanent and contractor, and a completion date for reading of the documents was established.
The training staff then reviewed the list to ensure that all personn'el had done the required reading.
Significant industry events were also discussed during continuing training and incorporated into the continuing training lesson plans.
7.2 n
ctH lhPh ic T hni i n T inin Contract health physics technician minimum qualification training requirements were specified in the "Contract Radiation Protection Technician Qualification Signature Reco'rd."
In-processing for contract technicians was expected to take two weeks.
. The first week was scheduled to include General Employee Training, respirator training and fit testing, and other administrative functions required by the Qualification Signature Record.
Technicians were also expected to be given the opportunity at this time to review some health physics basics.
The second week of in-processing was scheduled to begin with.a health physics technician screening exam.
Ginna was participating in an initiative with other Mid-Atlantic and Northeast utilities in which a standardized screening exam was administered to incoming technicians. Ifa technician had taken and passed the exam at any other participating facility in the last two years, testing at Ginna would not be required.
Millstone station was coordinating the standardized screening exam program and maintains records of technicians who had successfully completed the exa The remainder of the second week was dedicated to site specific training.
On the fifth day a site specific exam would be administered with 80% or greater required as a passing grade.
Following the test, the afternoon was dedicated to familiarizing technicians with all of the survey meters and counting equipment used on site.
Upon completion of the initial training, the technicians are required to be evaluated in the plant by designated on the job training evaluators.
The technician must perform tasks specified in the skills demonstration section of the Qualification Signature Record.
Only after completing all of the above training can the individual be considered for final qualification approval by the Health Physics Foreman, Health Physics/
Chemistry Manager and the Training Coordinator for Health Physics and Chemistry.
7.3D n
min inT hniinT inin The inspector reviewed the lesson plans for decontamination technician training.. This class was established to improve poor worker practices and reduce the number of personnel contaminations on. site.
The one day training session instructed technicians
'n the relationships between contamination and radiation, the advantages of an effective decontamination program, general rules of decontamination, effective decontamination methods, and proper use of protective clothing.
7.4 H 1th Ph i
T hnician T inin Prior to an outage, permanent health physics technicians were expected to receive training on infrequently performed or difficultoperations, recent industry events, and shutdown chemistry requirements.
Specific operations discussed were contained in the station's Job Coverage Guidelines and include steam generator work, refueling operations, reactor coolant pump work, auxiliary building work, hot particle identification, movement of radioactive materials, and responsibilities at the health physics sign in desk.
The inspector reviewed progress on the initial systems training program for shift technicians.
The first classes were held in September 1991 and lasted a total of fifteen days.
The course material covered the reactor coolant system, associated primary systems and secondary systems, and the radiological and chemistry control concerns for each of them.
The training department received positive feedback from
h course participants and was planning on incorporating portions of the course material into their continuing training lesson plans foi the upcoming year.
A new program was recently initiated by the training department on a trial basis.
The ultimate goals of the program were to instill in plant workers the attitude that radiation protection is every individual worker's personal responsibility and to enhance the team concept of maintenance between the health physics department and other work groups.
The pilot program involved three mechanical maintenance personnel and two health physics technicians. It was held at Rochester Gas and Electric's Beebee Station.
A simulated radiologically controlled area was established and the work group was given a specific task to perform in the area.
In preparation for the job, the group reviewed video tapes of similar jobs previously performed at Ginna.
Good radiological work practices and potential problems were discussed.
The work performed by the participants was videotaped and a critique was held after the exercise was completed.
The inspector found this to be a very good licensee initiative.
The inspector observed that the licensee had been sending staff members to other utilities, outside agencies, and seminars either for training or to observe how other facilities approach specific problems.
In May, members of the training department visited the Salem Nuclear Generating Station to observe their training program.
Two staff members, a Health Physicist and the lead ALARAtechnician, attended a recent Radiation Exposure Management (REM) seminar.
The two staff personnel who attended the INPO training, which was previously mentioned, also visited the Crystal River and St, Lucie Nuclear Stations to observe how they addressed the problem of personnel contaminations.
The inspector found that the information gathered on these visits had a positive effect on the licensee's radiation protection program.
8.0Ext mal Ex s re n r
During a previous inspection (50-244/90-30), the inspector noted that the licensee's procedures did not require daily neutron survey meter source checks with the neutron calibration source prior to meter use.
Station procedure HP-7.31, "Daily Instrument Source Checks," now requires "AllHealth Physics radiation/radioactive material detection instrumentation that is in use willbe source checked daily." Step 7.3 of this procedure goes on to explain the generic procedure for source checking hand held portable instrument ~
~
While this procedure did not specifically establish how to perform the source check for neutron survey instruments, it did establish the requirement for the source check to be performed.
'he licensee's instrument group.had issued a memorandum which specifically described how to perform the daily source check for neutron survey instruments. The memorandum was readily available for reference by health physics personnel whenever performance of the neutron survey meter source check was required.
The inspector had no further concerns in this area.
9.0Inte 1Ex r
nr
The inspector visited the licensee's new respirator maintenance facility. The facility contains state of the art equipment for the cleaning and maintenance of respirators.
A self contained water system allowed for recycling of potentially contaminated wash water.
The water was used for the wash cycle and is processed through a resin filter system and returned to the storage reservoir. in preparation for the next wash cycle.
Use of the facility greatly increased the efficiency of the respirator cleaning process and reduced the amount of liquid radioactive waste that must be processed by the in plant system.
The licensee initiated a leak test program for respirators in response to a previous inspector concern {50-244/90-30). Allrespirators on site were leak tested last summer.
Station procedure HP-12.5.16, "Operation and Calibration of the TDA-2ENB Respirator Tester",
stated in step 2.2.1 that "Face sealing respirators must be leak tested upon receipt from the manufacturer or vendor, following maintenance or replacement of parts other than filters, (and) following any incident where the respirator user may have received an uptake of airborne radioactive material."
The inspector observed that while HP-12.5.16 required leak testing after respirator maintenance, the licensee's respirator maintenance procedures neither reference HP-12.5.16
.
nor had leak testing as a final step in these procedures.
Although all personnel who had been involved in repairing respirators were aware of the requirement for leak testing respirators after maintenance, there was the possibility that personnel new to the organization would fail to perform the leak test after respirator maintenance since the test was not referenced in the respirator maihtenance procedures.
The licensee immediately took steps to correct the appropriate respirator maintenance procedures.
This item willbe reviewed during a future inspectio The inspector reviewed the following proposed licensee initiatives:
Fire protection personnel and health physics personnel used different types of self contained breathing apparatus'SCBAs).
The licensee had plans to standardize the type of SCBA used on site.
The licensee had plans to install a large volume, high integrity breathing air container at the Post Accident Sampling System station.
This willallow Chemistry personnel to perform post accident sampling without the need'of changing their SCBA-bottles.
The proposed air system would allow for approximately twelve continuous person-hours of work.
The licensee was in the process of switching from the use of a fitbooth to the use of a Porta-Count system for respirator fit testing of personnel.
These items willbe reviewed during a future inspection.
10.0 n'in i n nr
n nr 1 fR i
iv M ri
~
~
. The inspector observed that the licensee was continuing to aggressively address the problem of personnel contaminations.
The health physics department recently held a problem solving session.to address poor worker practices.
One of the recommendations from the meeting was to establish health physics liaisons for the various work groups at the station.
One or two health physics technicians would be assigned to each work group and would act as the initial contact between their assigned group and the Health Physics department.
The technicians
=
would attend pre-outage work group planning meetings and help increase the radiation safety awareness of their assigned work group.
Other recommendations from the problem solving session were being formulated at the time of the inspection.
As stated previously, a Health Physicist and Health Physics Planner visited the Crystal River and St. Lucie Nuclear Stations to observe how these facilities had addressed the problem of excessive personnel contaminations.
The recommendations from these visits were being evaluated at the time of this inspection.
Other initiatives to improve contamination control which the licensee was considering include:
development of an administrative contamination control procedure,
purchasing lexan enclosures for steam generator work, improving the layout at the containment personnel access hatch, and making contamination control a part of the ALARAreview process.
The inspector willreview performance in this area during future inspections.
were effective i 11.0 ALARA The inspector observed that the licensee has several methods to remind personnel that they should minimize. radioactive waste.
Immediately upon entering the protected area, personnel were confronted with a yellow and magenta S5 gallon drum that represents a container of radioactive waste.
A sign on the drum informed personnel of the cost to process a corItainer of radioactive waste and reminds them to minimize radioactive waste generation in their work activities.
Similar messages appeared on the facility's in plant televised information system.
During pre-job briefings, personnel were reminded to only take required tools and materials into the radiologically controlled area.
The inspector found that these methods n keeping personnel aware of the necessity to minimize radioactive waste.
/
The station cumulative exposure to date was 323 person-Rem and it appeared that at the end of the year the licensee willbe well below the 1991 ALARAgoal of 400 person-Rem.
The preliminary 1992 ALARAgoal of 290 person-Rem appeared to be very challenging.
This estimate includes an estimated exposure of 2SO person-Rem for the upcoming outage and 40 person-Rem for the remainder of the year.
The estimated exposure for the outage may change ifthe projected outage job scope changes significantly.
The licensee was aggressively researching new and better means of reducing cumulative exposure at the station.
They tested and subsequently purchased an asbestos removal and transfer system for removal of pressurizer insulation during the last outage.
The estimated exposure for the job without using the new system was 76.75 person-Rem.
The actual cumulative exposure for the job was 36.62 person-Rem.
The licensee attributes the 40 person-Rem exposure reduction to the use of the asbestos removal and transfer system and mock-up training with the system by the insulators prior to actual use.
This system willbe used for insulation removal from one or both of the steam generators during the upcoming outag Five pre-fabricated lexan tents had been ordered for use during steam generator work. Three of the tents were expected to be delivered prior to the outage.
The purchase and use of these structures should benefit the licensee in the areas of dose reduction, contamination control and minimization of radioactive waste.
The ease of assembly of these structures should reduce the amount of time personnel would be required to work in the area.
The structures were expected to be much easier to decontaminate and disassemble, which would aid in contamination control.
Radioactive waste would be reduced since the structures were reusable, and the large amount of contaminated herculite and wood which were normally generated from steam generator enclosures willbe eliminated.
Several other means of reducing exposure were being considered by the. licensee.
They are considering moving the storage area for steam generator tools and equipment to a lower dose rate area in containment.
The licensee was also planning on increasing the use of videotaping of work activities to aid in post-job ALARAreview and coaching workers in better radiological work practices.
The ALARAgroup has been involved with testing a new
"video stick." This was a combination video camera and remote reading radiation survey meter.
The inspector willreview the status of these initiatives during a future inspection.
The inspector noted that the licensee utilized a post-job questionnaire for workers and health physics technicians.
The questionnaire provided a means for all persons involved with a particular project to communicate suggestions to Health Physics supervision as to how the job might be done better.
These questionnaires were available to all personnel and may be filled out at any time.
The inspector attended the ALARApre-job briefing for a containment entry at power.
During the briefing there was good communications between the operations and health physics departments.
Both groups discussed in detail the scope of the work to be performed and the radiological conditions in the work areas.
Several scenarios and potential problems were addressed and the sequence of events for the work group were planned in such a manner as to keep worker exposures ALARA. A conservative exposure limit was assigned to the group by the ALARACoordinator.
9.0 a~i The inspector met with licensee representatives at the end of the inspection, on November 1,
1991.
The inspector reviewed the purpose and scope of the inspection and discussed the finding '