IR 05000244/1992019
| ML17262B136 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/05/1993 |
| From: | Noggle J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17262B135 | List: |
| References | |
| 50-244-92-19, NUDOCS 9301120113 | |
| Download: ML17262B136 (16) | |
Text
1II U. S. NUCLEAR REGULATORY COMMISSION
REGION I
2 2 N
.
~244 l.-l Docket No.
$g-244 License No. QPR~1)
Licensee:
R h
ter as d El
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~BA Roche ter New Y rk14
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Facility Name:
inn Nicl r P w r Pl n
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.Inspection Conducted: D m er 14 -
Approved by:
. Noggl adiation Specialist W. Pasciak, Chief, Facilities Radiation Protection Section, DRSS date
/- 5 0'5 date
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.YN inspection focused on technician training and qualifications, audits and surveillances, and instrument calibrations.
R~es It: The technician training and qualification program has undergone significant improvements including the establishment of the Training Upgrade Project and the Training Advisory Committee.
Also demonstrated was the involvement of management in the traiiiing program improvements.
Audits and surveillances of the HP program were adequate, but generally, were of very broad scope and did not always include review of detailed program areas.
However, excellent program oversight was demonstrated in response to an improper entry to a high radiation area.
Prompt and appropriate actions were initiated to prevent recurrence, 'and, as a result, was considered a non-cited violation. The instrument calibration program was found to be sound and of very good quality.
Good health physics program initiatives were identified including the determination of a better method for decontaminating the cavity and the addition of a quality improvement specialist to the health physics department.
In addition to the non-cited violation, an unresolved item was identified
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involving training records.
The plant staff was unable to retrieve archived training records for review by the inspector.
pp
9301120113 930105 PDR ADOCK 05000244
1.1 Licen Per nnel J. Bement, Health Physics Operations Lead Technician J. Cook, Reactor Engineer C. Edgar, Manager Electrical/ Instrumentation and Controls R. Gasper, Primary Chemistry Lead Technician
~ B..Goodman, Health Physics Operations Foreman
~ P. Gorsky, Manager Mechanical Maintenance T. Harding, Modification Support Coordinator
~ A. Harhay, Health Physics and Chemistry Manager A. Hedges, Training Upgrade Project Consultant A. Herman, Health Physicist
- J. Huff, Manager. Maintenance Training
- N. Kiedrowski, Health Physics Technician Instructor K. Lang, Health Physicist J. Larizza, Nuclear Assurance N. Leoni, Health Physics Quality Improvement Specialist
- F. Mis, Health Physicist R. Puddu, Health Physics Technician
- B. Quinn, Corporate Health Physicist
- T. Schulte, Operations Manager
- J. Wayland, Reactor Engineer
- T. White, Operations
- J. Widay, Plant Manager
- D. Wilson, Nuclear Safety and Licensing
~ R, Wood, Supervisor Nuclear. Security 1.2 Per nnel
~ E. Knutson, Resident Inspector
- T. Moslak, Senior Resident Inspector
- Denotes attendance at the exit meeting on December 18, 1992.
2.0 Purple The inspection was an unannounced inspection of the Ginna Station radiation control programs.
The inspection was principally focused on training and qualifications,
audits and surveillances, and instrumentation calibration.
3.0 The Health Physics (HP) organization consists of 45 members including 14 contractor personnel.
This organization has been stable with no personnel turnover since the previous inspection.
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 willbe filled in January 1993.
4.0 Audit n
rvei11 n The inspector reviewed the latest licensee audit of the HP program.
Between June 22 and July 10, 1992 audit no. 92-13CJK was performed for the HP, Chemistry, and Radwaste/Transportation program areas.
The audit was of very broad scope and appeared to be adequate, however, several detailed program areas were not addressed.
Since the last NRC HP inspection in May 1992, there have been five HP related surveillances and three quality control reports which reviewed several program areas.
The licensee also has a Radiological Incident Report (RIR) program.
The inspector
'eviewed the latest two RIRs prepared since the previous inspection, One involved the controlled area entry of a visitor on a Radiation Work Permit (RWP) when a thermoluminescent dosimeter (TLD) had not been issued.
The exposure was recorded by a self-reading dosimeter with no significant safety concerns associated with the incident. 'he second RIR reviewed involved a licensee-identified high radiation area entry that violated the Technical Specification 6.13 requirement for radiation monitoring,'pecifically, on June 17, 1992 an auxiliary operator entered the Waste Hold-Up Tank room without an alarming dosimeter or a briefing on radiation levels.
The inspector reviewed the licensee's history in this area and the corrective actions associated with this event.
There were no other recorded high radiation area violations during this SALP period, so this appears to be an isolated event.
.Corrective actions undertaken by the licensee include the following. A memorandum was issued by the plant manager to all self-monitor qualified workers alerting them of the event and stressing the technical specification.
Each of the rotating operation shifts were personally briefed by plant health physicists on the event and explained
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their responsibilities during high radiation entries.
On the Waste Hold-Up Tank room door, an additional posting was added that specifies the requirement for a dose rate instrument or an alarming pocket dosimeter with HP briefing prior to entry.
Finally, the licensee conducted a detailed task analysis for the various self-monitor qualified station workers and determined that each department needed their own specific self-monitoring requirements spelled out to remove any ambiguity of responsibility.
The inspector was satisfied that a thorough investigation was conducted and that
appropriate corrective actions were taken to prevent recurrence.
Although this was a violation of Technical Specification 6.13, it also fulfillsthe criteria for a non-cited violation as defined in Title 10, Part 2, Appendix C, V.G.1 and willbe so recorded (92-19-01).
No further corrective actions, or response to the NRC is required.
- In summary, the HP audit and surveillance program provided rather broad and adequate oversight of the HP programs.
ini n
1'fi The inspector reviewed the training and qualifications for radiation protection technicians with respect to the criteria in ANSI 18.1 - 1971, Technical Specification 6.11, and NUREG 1220.
The HP technician training program does not provide for periodic requalifiication on core HP procedures.
HP technicians that were qualified on HP procedures at different times in the past were qualified on the station HP procedures and instrumentation that were in use at the time of their qualification. In order to review these differences in HP technician training, the inspector reviewed specific technician training and qualification records.
Of the records reviewed, only three HP technicians files had documentation of qualification on station HP procedures.
During the inspection, the inspector requested the licensee to provide records of the original qualification for thirty additional HP technicians.
By the end of the inspection week, eighteen HP technician qualification records had been retrieved from plant archives with twelve more qualification records still due.
Technical Specification 6.2.2.E requires the licensee to have at least one HP technician qualified in HP procedures to be on site whenever there is fuel in the reactor.
Until these HP qualification records are recovered from plant archives and reviewed, this willremain an Unresolved Item (92-19-02).
These records and the adequacy of the HP technician training and qualification program willbe reviewed during a future HP 'inspection.
The inspector also reviewed the latest developments in the Training Upgrade Project that was initiated in response to some INPO findings stating that the licensee needed to improve the systematic approach to training, and especially HP department review of training effectiveness.
The inspector reviewed the licensee's developments with respect to enhancing the systematic approach to training and in particular management oversight and involvement with the continuing training program.
In mid-1992, the licensee established a Training Advisory Committee chaired by the plant manager that biennially audits the training program.
Additionally, an HP Curriculum Committee was organized to review on a regular basis the training needs of the department.
In order to develop continuing training for several HP specialty areas, HP curriculum Sub-Committees were also organized for the following subject areas:
HP shift technicians, dosimetry, respiratory, radwaste, instruments, chemistry, primary chemistry, and environmental.
The licensee has shown a strong commitment to involve management in the continuing training progra i n The inspector reviewed the calibration program for portable and fixed radiation detection instrumentation.
The program was reviewed with respect to ANSI N323-1978, and ANSI N42. 14 - 1978.
6.1 P
rv In n
li in The inspector reviewed the latest source table calibration records for the Sheperd Model 28 calibrator containing 0.2 Curies of cesium-137.
The latest calibration was performed during the four week interval from November 16 through December 18, 1991.
The source strength versus distance values were determined by use of an instrument standard that was certified by the National Institute of Standards and Technology (NIST) on March 25, 1991.
The inspector verified that appropriate
'rocedures were used to accurately and precisely determine correct dose rates distances from the calibration source.
A recent calibration verification was conducted utilizing several NIST certified instruments on December 8, 1992.
The inspector'eviewed the current inventory list of portable radiation survey instruments and also reviewed selected instrument calibration records to ensure proper calibrations were obtained within the required six month periodicity.
Each instrument was calibrated with a known source strength on each scale of the instrument.
The station inventory
'ist indicated a noticeable backlog of instruments that were past due for calibration.
These instruments were removed from the available station instrument inventory and were locked inside instrument cabinets'inside the instrument calibration facility to preclude their use.
No discrepancies were noted.
6.2 1f-R in D
ime r li i
The self-reading dosimeter (SRD) calibration program was also reviewed.
A set of ten calibration SRDs were sent to an outside laboratory for NIST certification on August 17, 1992.
The licensee utilizes these ten reference standard dosimeters to determine timed exposures at fixed locations from a Shepherd 142-10 calibrator on a round calibration table when exposed to a 130 Curie cesium-137 source.
This calibration determination was last completed on November 18, 1992.
SRDs are calibrated once every six months to within + 10% of an established 80% full scale
. exposed value.
Select dosimeter records were examined and no discrepancies were noted.
- The inspector also verified that the air sampler flow rate meters were adequately
'alibrated.
On April 17, 1992, the RADECO air sampler calibrator was'calibrated by an outside laboratory and the station portable air sampling equipment was calibrated within the six month station calibration requirement.
No discrepancies were noted.
6.4 unt Room Ins m n i n li n
The inspector also reviewed the performance records of the licensee's radiation
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measurement instrumentation in the HP counting laboratory.
The licensee uses an alpha/beta low background counting instrument for deteimining non-isotope specific air sample activity concentrations and for determining unrestricted release of materials
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from the controlled area.
The calibration and daily.quality control records were
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reviewed for this gas-flow proportional instrument.
This instrument was calibrated on August 11, 1992 with separate'alpha and beta voltage plateaus plotted.
Operating voltages were appropriately determined and alpha/beta crosstalk'was also evaluated and corrected.
Quality Control source counts-were performed daily within a + 3 0 acceptance criteria.
No discrepancies were noted.
The licensee uses a gamma spectroscopy system for final air sample determinations of Maximum Permissible Concentrations (MPC) of airborne-radionuclides.
The calibration records of the Lithium drifted Germanium (GeLi) detector gamma spectroscopy system were reviewed.
The licensee used a ten radionuclide solution traceable to NIST that was certified on October 1, 1991.
This solution was used to pipette a known quantity of source material onto a two inch glass fiber filter which is the medium used for particulate air sample collection.
This method was also used for spiking a charcoal cartridge.
In this case, prior to counting, the cartridge is broken and the contents are thoroughly mixed.
This is also the practice when counting routine charcoal cartridge air samples.
A third counting geometry used was the point source for counting and quantifying hot particle activity. This source was purchased from a source manufacturer as a point source.
The NIST traceability was verified by the inspector for this source type.
The inspector reviewed the efficiency and energy calibration records for both GeLi detector counting systems.
Calibration packages were examined with particulate filter calibrations completed on June 17, 1992, iodine cartridge calibrations completed on May 10, 1992, and point source geometry calibrations completed on April27, 1992. Allcalibration sources were NIST traceable and all calibration methods were sound and complete.
The inspector also reviewed the daily background 'and source count practices and found well documented
. quality control charts with daily source counts plotted using a europium source at the
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1275 and 86 kev energy peaks with a + 3 0 acceptance criteria.
The background was.
only counted once per week rather than daily. The licensee stated that their sample counting practices have not affected the background count and the background
t'
r environment was stable, therefore a once per week background count was sufficient.
The inspector found no discrepancies with the calibration or daily source count procedures and practices.
The inspector also reviewed several positive,air samples counted during the previous outage.
No unidentified or unresolved peaks were evident.
A well tailored library of radionuclides produces a well identified report from the GeLi system.
The inspector was satisfied that the counting laboratory was well run and produced excellent results.
While examin*ing air sample results, the inspector noted a number of transcription and manual calculation errors in the air sample determinations and MPC-hour assignment forms associated with air samples.
The inspector reviewed approximately 25 positive air sample and MPC assignment packages from the previous outage. with the following result.
More than half of the air sample packages had mistakes (either incorrect calculations, or transcription errors), and approximately 10% resulted in incorrect final results.
Due to the apparently well controlled air sampling and respirator assignment practices, no MPC-hour assignments approaching regulatory limits would have been exceeded due to the errors.
The present level of errors, however, is considered a significant weakness.
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I The inspector reviewed ALARACommittee meeting minutes and interviewed various individuals to assess the HP program.
Certain areas of the pr'ogram are currently undergoing upgrade.
One of the areas is the method used for decontamination of the reactor cavity.
The purpose for the decontamination is to allow workers in the reactor cavity area to work without the need for respiratory protection.
The use of ALARAstrippable paint on'he lower eight feet of the cavity has not produced effective results during past outages.
The station is now evaluating the use of hydrolazing for future outages.
The licensee has also recognized the need for, a cobalt reduction program and expects have a program in place in 1993.
The ALARA'ommittee is also reviewing the adequacy of the current monetary value for personnel exposure which is now set at $5,000 per person-rem.
Another significant HP initiative has been the addition of a quality improvement specialist to the HP department.
This individual has worked in a chemistry laboratory responsible for the quality control aspects of laboratory measurements, and is now assigned to the HP organization in order to enhance the uniformity and quality, of the various measurements in the department.,
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rr aeT ur The station has purchased a computer driven surrogate tour package that provides a moving slide show representation of the plant using digital picture technology stored on a laser disk.
The computer program allows for the input of radiological information such as general area and hot spot dose rate information to be used for future pre-job briefings of radiological conditions in the plant.
The current surrogate tour system only incorporates the auxiliary building and is undergoing trial and evaluation by the licensee.
7.2 w W rk Permi The licensee has identified the need for improving the format of the RWP system.
The licensee indicated that improvements would be made to make the permits easier for the user to understand, allow for more detailed ALARAinstructions, and result in a more simplified mask-use form. The permit upgrade willalso remove the requirement for Operations Shift Supervisor signature.
By review of the current draft changes, it appears that some of the transcription errors mentioned in Section 6.4 may be reduced and it is noteworthy that the licensee recognized the need to simply the work permit and some of its attachment forms, however the current scope of revision falls short of addressing all of the problems.
The manual calculation errors, recording of final air sample evaluation information and summation of all MPC fractions have not yet been addressed by the licensee.
This issue willbe followed.in future inspections.
8.0 LARA The licensee had set a 1992 annual collective personnel exposure goal of 322 person-rem that included a goal of 305 person-rem for a spring refueling and maintenance outage.
The outage resulted in significant savings with a final tally of 228 person-rem.
The current accumulated 1992 station exposure totals through December 14, 1992 was 260 person-rem.
Although the non-outage exposure was higher than predicted, the station's overall performance in this area is very good.
The total number of personnel contaminations during the same period was 193 versus an annual goal of 220.
9.0 xi
in The inspector met with licensee representatives at the end of the inspection, on December 18, 1992.
The inspector reviewed the purpose and scope of the inspection and discussed the findings.