IR 05000244/1992005
| ML17262A873 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/18/1992 |
| From: | Noggle J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17262A871 | List: |
| References | |
| 50-244-92-05, 50-244-92-5, NUDOCS 9206020066 | |
| Download: ML17262A873 (22) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
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PA22Ã2 Z-Docket No.
~244 License No.
QPR~l Licensee:
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Facility Name:
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Inspection Conducted:
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Inspector:
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R matron Speczalzst d te Approved by:
W. Pasciak, Chief, Facilities Radiation Protection Section, DRSS
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22 Pffft program during outage conditions.
This inspection focused on implementation of the radiation control program during the performance of outage work.
~R~lz: Within the scope of this inspection no violations were identified. Health physics coverage of outage work activities was generally strong.
A good level of dedicated HP surveillance of work activities was evident.
There was good preplanning and dose minimization results with respect to steam generator maintenance and insulation replacement activities.
Special Work Permits were generally well written and complied with. Areas for enhancement were noted in the design of the HP staytime calculation record, shielding optimization, and currency of the MPC-hour tracking log.
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DETAILS n
Pr nl J. Bement, Health Physics Operations Lead Technician D. Cotroneo, ALARAHP Technician
'. Goodman, Health Physics Operations Foreman
- A. Harhay, Health Physics and Chemistry Manager
- A. Herman, Health Physicist
- N. Kiedrowski, HP Technician Instructor K. Lang, Health Physicist
~ R. Marchionda, Superintendent, Support Services
~ T. Marlow, Superintendent, Production
'. Mis, Health Physicist J. Pagani, Steam Generator Lead HP Technician
- B. Quinn, Corporate Health Physicist M. Smith, Steam Generator Project Engineer R. Watts, Director, Corporate Radiation Protection
- J. Widay, Plant Manager J. Wright, ALARAHP Technician 1.2 +k~~r~nn l E. Knutson, Resident Inspector
- T. Moslak, Senior Resident Inspector
- W. Pasciak, Chief, Facilities Radiation Protection Section
- Denotes attendance at the exit meeting on May 1, 1992.
2.0 Pyrr.~
The inspection was an unannounced inspection of the Ginna Station radiation control programs.
The inspection was principally focused on implementation of these programs during the performance of outage work.
3.0 r
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The non-outage Health Physics (HP) organization consisted of approximately 45 members of which 14 were contractor personnel.
There are currently three staff Health Physicists that report to the HP and Chemistry Manager.
A fourth Health Physicist position has been vacant since early 1990 and remains unfille The outage HP organization was expanded to approximately 80 persons with staff Health Physicists providing continuous supervisor coverage during the outage.
HP technician duties and routines were delegated by the following night-shift or 'day-shift lead positions:
HP Foreman, Balance-of-Plant RWP Coordinator, HP Containment Vessel (CV) Coordinator, Refuel Floor Lead HP Technician, Steam Generator Lead HP Technician, CV Lead HP Technician, and AuxiliaryBuilding Lead HP technician.
Under these lead positions were appropriately staffed HP technicians.
This level of staffing appeared to be commensurate with the outage work demands.
Appropriate levels of first-line and management supervision were evident.
4.0 The inspector toured the radiological controlled areas of the Ginna nuclear power plant during outage conditions and reviewed the following elements of the licensee's radiological control program:
posting, barricading and access control, as appropriate, to radiation, high radiation, and airborne radioactivity areas; personnel adherence to radiation protection procedures, radiation work permits, and good radiological control practices; use of personnel contamination control devices; adequacy of airborne radioactivity sampling and analysis to plan for and support ongoing work; installation, use and periodic operability verification of engineering controls to minimize airborne radioactivity; adequacy of radiological surveys to support pre-planning of work and on-going work; The review was with respect to criteria contained in applicable licensee procedures, Technical Specifications, 10 CFR 19 - Notices, Instructions And Reports To Workers:
Inspection And Investigation, and 10 CFR 20 - Standards For Protection Against Radiation.
4.1 n inmn n ii n rkInPr r
At the time of this inspection, all of the radiation exposure intensive jobs had been completed for the outage.
Reactor refueling had been completed with the reactor head reinstalled.
The reactor coolant system was in the process of being closed and filled. Outage demobilization was jn full swing with equipment and materials being removed from the various work areas.
The inspector reviewed work in progress, interviewed workers and attended outage status meeting Steam generator manways had been installed.
Pressurizer manway installations were being performed under dedicated HP coverage and these activities were carried out demonstrating good concern for minimizing radiation exposure and for contamination control.
Special Work Permit (SWP) S92-1581, "Install Pressurizer Manway" was reviewed.
This permit required full face mask for work in a high contamination and
'igh radiation environment with continuous HP coverage required while in respirators.
A copy of the latest survey was available at the job site.
This work was appropriately monitored and controlled by health physics personnel.
The high contamination area posting at the Step-Off-Pad (SOP) leading into the pressurizer manway area was discovered down on one occasion and the high radiation area posting at the top of the vertical ladder leading into the pressurizer cubicle was also found down on another occasion.
The licensee promptly redressed the postings when notified. No other discrepancies associated with RCS closure were noted, Steam generator tents and platforms were being removed.
The licensee used a floor wax spray to fix the high contamination to the interior tent surfaces for controlling airborne contamination during removal.
This method appeared to work very well.
The movement of outage equipment out of containment was managed through the equipment hatch with an outside and inside HP crew controlling the movement of material out of the controlled area.
Reusable outage equipment was transferred out of containment and into the Contaminated Storage Building (CSB) where dedicated HP staff received, surveyed, decontaminated, repackaged, and stored radioactive material for'future maintenance requirements.
In spite of high traffic and peak demand for this facility, the CSB was reasonably well organized and controlled during this inspection.
4.2 earn n
r ve Steam generator associated work (not including insulation replacement)
represented the largest exposure cost for the outage representing approximately 45% of the outage exposure.
This work had been completed at the time of the inspection, however radiological controls were reviewed through meetings with the licensee and through the review of records.
j Approximately 109 person-rem (versus 123 person-rem estimated) was expended in the performance of remotely performed eddy current tube inspection work, and the installation of over 400 tube sleeves and 60 tube plugs into the two Ginna steam generators.
The highest exposure to an individual was 1.5 rem to the whole body and 3.7 rem to the extremitie The licensee operates a steam generator building with two steam generator mockups available for equipment checkout and for training of work crews.
This building also houses offices to support the project engineer and staff which includes an ALARA office.
The radiological controls setup for primary-side steam generator work was adequate.
A containment tent was built on each generator platform to include the access stairway.
A lead shield wall of 'A inch thickness was provided on one side of the stairway to help reduce the dose rates emanating from the RCS loop. A 2000 CFM High Efficiency Particulate Activity(HEPA) filter provided air evacuation from the tent while simultaneously pulling a vacuum on the steam generator.
During manned steam generator work, a laborer was normally stationed inside the shielded portion of the steam generator tent and one HP technician was stationed outside the biological shield wall at a video and audio communications control station.
Two video cameras were used on each platform with one audio party line for each steam generator which connected the steam generator worker, HP technician, steam generator building, and vendor trailer with one another.
During normal robotic steam generator maintenance activities, there was no one stationed inside the biological shield wall. Manned steam generator entries were only required for the removal and replacement of nozzle dams with platform attendance only required for installing and removing manways and inserts, staging of the robotic equipment and for changing eddy current probes or other tooling from the robot arm.
The inspector was satisfied that steam generator maintenance associated exposure was minimized.
The inspector reviewed the "Steam Generator Job Coverage Guidelines", 9TXST6, Rev. 2, which provided HP technicians with the guidelines necessary to ensure consistent quality HP job coverage of this work.
Contamination control setup',
instrumentation needs, and survey requirements are clearly specified in this document.
The inspector noted that for secondary-side hand hole'ork, the licensee considers extremity dose to be the limiting criteria for HP job coverage.
Thermoluminescent Dosimeters (TLDs) alone are prescribed for this work which require dose estimating without on-the-job dose verification which is usually provided by self-reading dosimetry.
The licensee agreed to review this consideration.
A second issue identified by the inspector involved the usual station HP practice of providing several layers of herculite covering the containment tent floors to allow the removal of a floor layer as contamination builds up in lieu of decontamination of the tents which are in high radiation areas.
For this outage, this practice was discontinued in the interest of radwaste minimization'. By reference to steam generator log book entries, the inspector noted that 3 to 4 dedicated decontamination efforts and many self-service decontaminations of steam generator tents were necessary during the almost two week
tube honing and sleeving work evolutions, Contamination levels of up to 720 mrad/hr/100 cm'ere recorded with general tent levels reaching 200 mrad/hr/100 cm~ regularly during this time period.
The inspector investigated the station's policy of radwaste versus personnel exposure considerations.
The inspector noted that the licensee has a 1992 corporate performance indicator goal for radwaste burial volume of 3,000 cubic feet.
The Ginna Station 1992 Outage Information Manual reports the same annual goal but lists it as radwaste generation volume.
Current station practice concerning disposition of Dry Active Waste (DAW)
involves shipping the waste to Scientific Ecology Group (SEG) for waste segregation, incineration, and burial of ash and any unincinerable wastes.
The inspector pointed out the difference between radwaste generated versus radwaste burial costs.
The inspector compared the station ALARAcosts per person-rem ($5,000) and the station DAW incineration budget value ($85 per cubic foot) which infers a relation of 17 mrem per cubic foot of incinerable radwaste.
The inspector suggested that appropriate ALARAcosts should be weighed against appropriate radwaste costs in future considerations.
The following SWPs and attached surveys were reviewed.
S92-1119, Entry into 'A'/G Tent and Channelhead.
B &W Tubesheet Sleeve Installation.
Appropriate protective clothing and HP monitoring requirements were specified and radiological conditions were indicated.
Although 1100 Maximum Permissible Concentration (MPC) airborne contamination was measured, due to short stay times and giving credit for the protection factor of supplied air suits no resultant MPC-hours were recorded.
S92-848, Sludge Lance of 'A'/G. No hand hole entries were permitted on this permit.
Appropriate controls were specified and radiological conditions indicated.
S92-343, Remove 'B'/G Manway. Filter respirators combined with lapel air samplers and continuous HP coverage were required and survey details were specified.
S92-872, Remove CE Mechanical Plugs from 'B'/G.
Some mild airborne contamination was experienced.
Appropriate respiratory protection, lapel air sampling and continuous HP. coverage were required.
As a tool for external exposure control of steam generator workers, the licensee provided a "Multi-Badge/Extremity Badge Exposure Record" for each individual.
This form lists the current total whole body and extremity dose and was used as a
'jump ticket'or steam generator entries.
This record documents the official radiation
exposure for an individual and was used by the HP technician in stay time calculations for the high radiation steam generator entries.
This record did not provide the allowable dose for the individual as is customary in the industry.
Incomplete exposure histories and exposures accrued at other licensees, among other reasons, willalso influence an individual s available exposure limit. To compensate for this lack of information, the HP technicians utilized the daily station exposure report to lookup the individual exposures.-
The form was not designed to provide for dose subtraction from available exposure, therefore the necessary calculations were performed mentally or on some scrap of paper or tape.
The licensee explained that if a station exposure report was unavailable, an available exposure of 1800 mrem was assumed.
To date, there have not been any apparent overexposures stemming from this practice, however the potential exists.
The licensee agreed to revise the Multi-Badge/Extremity Badge Exposure Record to provide the required data and provide a useable worksheet for the necessary stay time calculations, In summary, the licensee has an excellent steam generator mockup facility and very good audio and video communications between the steam generator worker, HP technician, and the steam generator building. The Special Work Permits were well written and appropriate radiological controls were applied.
The licensee had staged adequate containments for contamination control and had minimized steam generator entries and platform. attendance which reduced exposures.
Areas for enhancement include revision of the HP stay time calculation form and reducing the decontamination requirements in the containment tent areas.
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At the time of the inspection, refueling activities had been completed.
The inspector reviewed various documents and had interviews with the licensee to review the HP job coverage of refueling operations.
General job coverage was provided by a lead HP technician and 2-3 HP technicians on a continuous outage basis.
Generally, a lapel air sampler was worn by one worker of each work crew and continuous HP coverage was provided.
The following SWP's were reviewed.
S92-277, Decon the Reactor Cavity.
Respirators and plastic suits over coveralls were required with a lapel air sampler providing the air survey data.
After a water squeegee, dry mop, and rag wipe down, the licensee painted thecavity walls with ALARAstrippable paint up to 8 feet vertically. The licensee did not successfully decon the cavity to be below respiratory requirements with this method but was considering alternative method S92-445, Install Seal Ring in Cavity. Double protective clothing, respirator, alarming dosimeter, and a lapel air sampler were required to perform this work.
Continuous HP coverage was specified and detailed radiological surveys were documented.
S92-466, Unlatch CRDM and LiftUpper Internals.
The requirement for daily tritium monitoring was established.
Also, an operating Area Radiation Monitor (ARM) was specified for the refueling bridge when moving fuel.
Other requirements and surveys were documented appropriately.
Generic HP technician guidance was described in "Refueling Job Coverage" 9TXREF, Rev. 0. This document describes the major job evolutions involved in reactor head disassembly, refueling,.reactor head reassembly, and cleanup and close-out of the reactor cavity. It provides HP technicians with the guidelines necessary to ensure consistent quality HP job coverage of this work. No discrepancies were noted.
The current reactor head shield configuration was established in 1990 and consisted of a single layer of lead blankets attached to a circular support beam located above the reactor head, and a second ring of single layer lead blankets immediately above supported by the CRDM ventilation shroud.
General dose rates in this vicinity were reduced by 50% to approximately 80 mR/hr.
Additionally, a work platform consisting of scaffolding was constructed in a low dose rate area and lowered into the cavity to support reactor head maintenance work and one layer of lead blankets was added to this platform to further reduce working dose rates.
Thermocouple inspection and repair work on the reactor head was estimated to cost 4.5 person-rem.
The actual costs were 1.9 person-rem plus 0.3 person-rem for shielding installation.
In summary, the refueling floor operations appeared to have good HP resources devoted to it. The specific HP technician guidance provided appeared to be a good vehicle to provide an expectation of quality for the HP technicians.
Devoted shielding resources to the reactor head associated work has helped reduce collective exposure in this area.
Further improvement appears necessary to provide effective decontamination of the refueling cavity.
4.4 r
n imnAr During the 1992 outage, the asbestos insulation on the 'A'team generator was replaced with non-asbestos containing mirror insulation.
Good ALARApreplanning work directed this work to be performed during the outage when the steam generator would be filled with water in order to reduce general dose rates by one-half.
In cooperation with operations and the Plan-A-Log group, this work was scheduled appropriately with the resultant reduction in radiation exposure Aside from the reactor head shielding and steam generator stairway shielding previously mentioned, there were two other shield designs utilized in containment.
The pressurizer spray line and the regenerative heat exchanger are both located in transit areas in the containment basement.
Both were shielded with one layer of lead blankets resulting in 100 mR/hr and 60 mR/hr general area fields, respectively.
To further warn the worker, the licensee roped offand posted these areas as high radiation areas and placed ARMs at each access path by these radiation sources providing actual dose rate information for the worker transitting through these areas.
In general, the containment areas were well posted with sufficient radiological information to warn the worker of the existing radiological hazards.
No significant deficiencies in postings or housekeeping were noted.
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The station has set a goal for limiting personnel contaminations to below 220 for 1992.
As of April27, 1992, there were 139 personnel contamination incidents recorded which resulted in 3 skin dose assignments.
The inspector noted that most of these Personnel Contamination Reports {PCRs) were from unknown causes.
The most common known root cause as determined by the licensee, was poor work practices.
The licensee mentioned that exiting from the refueling cavity undress area had caused multiple PCRs during this outage and station practices would be revised for the next outage.
Also, the HP department has recently begun to send the worker's supervisor a memo identifying personnel contamination events in the attempt to place some responsibility for poor work practices onto the work supervisor.
Prior to the outage, the health physics department produced a 15 minute "HP Issues" videotape aimed at focusing attention on contamination control, personnel contaminations, and radwaste minimization. This video presentation was shown to various station departments followed by discussion sessions after each showing.
Highlighting of these HP department goals was viewed as a very good initiative.
6.0 AR As of May 1, 1992, with most of the exposure intensive outage work completed, the outage had accrued 226 person-rem as compared to the outage estimate of 305 person-rem.
The 1992 Ginna station collective external exposures were 234 person-rem versus the annual goal of 330 person-rem.
The inspector reviewed the licensee's MPC-hour logs and determined that the maximum internal exposure documented was 12.36 MPC-hours.
At the time of the this inspection the licensee was more than two weeks behind in compiling this information.
The data input process for the MPC-hour tracking system requires completed SWP package review and MPC-hour calculations by a member of the
operations HP staff and forwarding any required MPC-hour sheets to the dosimetry group for data entry into the tracking system.
This process is not automatic and depends on individual HP staff initiative to feed this tracking system.
The inspector reviewed the temporary shielding program.
As was mentioned in sections 4.2, 4.3, and 4.4 above, the inspector observed various temporary shield designs used during the outage.
Allof them consisted of a single layer of approximately
'A inch lead shielding.
In one instance, the post-shielded source was 175 mR/hr contact and another source measured 60 mR/hr next to the lead blanket shield.
High background levels continued to exist around these shielded sources.
The licensee took appropriate posting precautions in these areas to warn workers of these high background levels which included the use of area radiation monitors, however the shielding found did not appear to be sufficient. The inspector reviewed procedure A-1.7, Rev. 1, entitled, "Control of Temporary Lead Shielding" and determined it to be an effective vehicle for effecting the design, engineering approval, installation, control, and removal of temporary lead shielding but did not address shield design optimization.
The licensee indicated that typical shielding applications were transmitted to a working engineer in the Nuclear Engineering Services group where a one time approval was generally made.
Since final shield design is typically field determined, multiple shield application amendments would be required which is not expedient.
The licensee suggested developing temporary shield designs prior to an outage and submitting them to the RGB'cE Corporate AI.ARACommittee for approval and disposition which would clear the way for a direct working relationship to exist between the field HP technician working to optimize a particular shield and the cognizant engineer.
The inspector questioned the licensee about source term reduction activities at Ginna Station.
Apparently since 1983 when steam generator channel heads were chemically decontaminated, only minor source term reduction actions have been implemented.
During this outage, two fioor drains in the Auxiliary Building were decontaminated by high pressure water spray which resulted in the reduction of general area dose rates at the east stairway from 3-5 mR/hr down to 2 mR/hr and another drain decontamination helped reduce the background levels for the use of a hand and foot monitor located in the AuxiliaryBuilding.
Generally, the licensee has a good ALARAtracking and shielding program.
Effective dose reductions have been made in this area.
Improvements in shield designs and in source term reduction considerations should be considere.D UildcctUE The inspector met with licensee representatives at the end of the inspection, on May I, 1992.
The inspector reviewed the purpose and scope of the inspection and discussed the finding