ML17254A611
| ML17254A611 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/11/1985 |
| From: | Cioffi J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17254A607 | List: |
| References | |
| 50-244-85-18, NUDOCS 8510230244 | |
| Download: ML17254A611 (13) | |
See also: IR 05000244/1985018
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
85-18
Docket No.
50-244
License
No.
Priority'ategory
C
Licensee:
Rochester
Gas
and Electric Cor oration
49 East Avenue
Rochester
14649
Facility Name:
Ginna Nuclear
Power Plant
Inspection At:
Ontario
Inspection
Conducted:
Se
tember
3-6
1985
Inspectors:
Jea
A. Cioffi, Radi
on Specialist
/o
~o p~
da
e
Approved by:
M.
M. Shanbaky,
Chief,
WR Radiation
Safety Section,
EP&RPB
date
Ins ection
Summar
Ins ection
on
Se tember 3-6
1985
Ins ection
Re ort No. 50-244/85-18
~AI
d:
I,
I
I
I
dd-
logical environmental
monitoring program,
including the status of previously
identified items,
management
controls,
the licensee's
program for quality
control of analytical
measurements,
and the implementation of the radiological
environmental
monitoring and the meteorological
monitoring programs.
The
inspection
involved 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> onsite
by one region-based
inspector.
Results:
Within the areas
inspected,
four violations were identified:
failure
to meet the
LLD for I-131 in drinking water (paragraph
S.a); failure to sample
surface waters
as specified in the Technical Specifications
(paragraph
5.b);
.failure to report information in the Annual
REMP report for the reporting year
1984 (paragraph
5.a);
and failure to establish
a calibration procedure,
and
have calibration procedures
which specify calibration frequency (paragraphs
4
and 6).
- 8510230244
8510>8 I,
'~PDR
ADQCK 05000244'
A,e
PDR~
DETAILS
1.0
Personnel
Contacted
C.
B.
J.
M.
- B
- R.
G.
K.
- S
Anderson,
gA Supervisor
Burt, Training Coordinator
Catlin, Environmental
Monitoring Technician
Farnan,
I&C Foreman
Fi lion, Plant Radiochemist
Goodman,
Health Physics
Foreman
Kober, V.P., Electric & Steam Production
Lawlor, Training Specialist
Mis, Health Physicist
Nassauer,
gC Supervisor
Quinn, Corporate Health Physicist
Sagaties,
Plant Health Physicist
Snow, Superintendent,
Nuclear Production
Warren,
Health Physicist
- Denotes attendance
at exit interview.
2.0
Status of Previousl
Identified Items
2.1
(Closed) Inspector
Follow-up (244/84-20-01).
Document investigation
of and corrective actions for discrepancies
in
EPA Interlaboratory
Comparison results
in Annual Radiological
Environmental Monitoring
Program
(REMP) report.
The inspector
reviewed the results of the
Interlaboratory
Comparison,
included in Table >(III of the
1984 Annual
Radiological
Environmental
Monitoring report.
The licensee
had
documented
the investigation of and corrective actions for results
which were not in agreement with the
EPA Interlaboratory
Comparison.
This item is considered
closed.
2.2
2.3
(Open)
Unresolved (84-20-02).
Ability of TLD system to properly
measure
and record environmental
radiation.
Details appear
in
paragraph
S.c of this report.
(Closed) Inspector
Follow-up (84-20-03).
Completion of logs for
laboratory analyses
(gross beta in water
and in air particulate-
filters) and revision of procedures
to incorporate
new beta detector.
The inspector
reviewed the log for gross beta activity in water
samples
and for air particulate filters.
All data
was entered
and
the required calculations of activity were recorded.
The three pro-
cedures
that
had previously referenced
the old beta detector,
CE-5. 1,
CE-4. 1,
and CE-4.2,
had been appropriately revised to reference
the
new Baird low activity counter for gross
beta analyses.
This item is
considered
closed.
2.4
(Open) Inspector
Follow-up (84-20-04).
Document training for environ-
mental technician
and provide specific training and job description
for this position.
The licensee
has initiated
a Job Analysis Check
Sheet to delineate
the educational
requirements
and position duties
for the Environmental
Monitoring Technician,
however,
no formal job
description
has
been
completed.
The inspector discussed
this matter
with licensee
personnel.
Licensee
representatives
stated that
a
complete job description
and training program will be established
for
this position,
and for the entire plant staff'to meet
INPO certifi-
cation requirements
by December,
1986.
This item will remain
open
and
be reviewed in a future inspection.
3.0
Mana ement Controls
The inspector
reviewed the licensee's
management
controls for the, Radio-
logical Environmental
Monitoring Program
(REMP), including assignment
of
responsibility, program'udits,
and corrective actions for identified
inadequacies
and problem areas
in the program.
The
new radiological
environmental
technical
specifications
were
implemented January,
1984.
a.
Assi
nment of Res onsibi lit
The inspector
reviewed the organization
and administration of the
REMP.
The program is the responsibility of the Plant Radiochemist
who reports to the Manager of Health Physics
and Chemistry.
The
utilizes one full-time technician for sample collections in the field
and for sample analyses
in the environmental
laboratory.
Additional
HP and Chemistry technicians
are available to perform these duties
as
necessary.
b.
Pro
ram Review and Audits
The inspector
reviewed licensee
audits of the
REMP for 1984 and the
first half of 1985.
The audits consisted
of check-off sheets of
activities for the
REMP which covered
sampling locations, verifica-
tion of sampler operation,
and sampling frequencies
as specified in
the technical
specifications.
However,
these audits
appeared
limited
in scope in that they did not address
certain significant program
activities.
Licensee
representatives
stated that the audit of the
REMP is under current revision,
and future audits will be more com-
prehensive
and thorough in technical
depth for the
REMP.
This matter
will be reviewed in a future inspection
(85-18-01).
4.0
Licensee's
Pro
ram for ualit
Control of Anal tical Measurements
The inspector
reviewed procedure
CE-8. 1, "guality Control for Low Activity
Counting Systems,"
which provided instructions for the preparation of a
performance
control chart for daily source
checks
and background
checks.
The procedure
stated that background
and source
checks
should
be obtained
and plotted daily.
The procedure
did not require these activities to be
performed.
As
a result,
source
check data
was obtained daily but not
plotted.
When the data
was finally plotted
on the performance
control
chart, it was discovered that there
was significant drifting of source
check data
beyond the acceptance
range
(+3 sigma) for the instrument over
a two-month period.
The lack of clearly established
requirements
in the procedure
may have
contributed to the failure to identify the unacceptable
performance of
the low activity counter.
Additionally, the results of any environmental
sample analyses,
performed
on this equipment during this time period,
may
have
been
inaccurate
due to the lack of adequate
quality control of the
counting
system.
The inspector discussed
these
inadequacies
with the licensee.
The licensee
stated that appropriate
action will be taken to correct these deficiencies.
This matter is considered
unresolved
and 'will be reviewed in a future
inspection
(85-18-02).
The inspector
reviewed the procedures
for the calibration of the
gamma
spectroscopy
system,
the liquid scintillation counter,
and the Baird low
activity counter.
The inspector identified that there
was
no written
calibration procedure for the Baird low activity counter.
The inspector
stated that this was
a violation of Technical Specification 6.8. 1 which
requires,
in part, that written procedures
be established,
implemented
and
maintained covering the activities referenced
in Appendix A of Regulatory
Guide 1.33:
Section
H of Appendix A in Regulatory Guide 1.33, Control of
Measuring
and Test Equipment,
requires that procedures
be provided to
assure
that instruments
are properly controlled, calibrated,
and adjusted
at specified periods to maintain accuracy.
In conjunction with the above violation, the inspector
found that the
calibration procedures
for the liquid scintillation counter (HP-10.9)
and
the
gamma spectrometer
(HP-10.5) did not specify the calibration frequency
for these
instruments.
This represents
two additional
examples of
violations of Technical Specification 6.8. 1.
The inspector
reviewed the records for the calibration of the Baird
low activity counter,
the liquid scintillation counter,
and the
gamma
spectrometer.
The inspector
observed .that the
gamma spectrometer
had not
been calibrated for the most frequently used geometries
in over one year.
Furthermore,
the
gamma spectrometer
had not been calibrated for the char-
coal cartridge
geometry
since
1980.
The detector
was redrifted in 1981.
The licensee
stated that
he did not realize that the calibrations
were
overdue,
but that
he felt the data reported
was accurate.
The failure to calibrate
the
gamma
spectroscopy
system
on
a specified
frequency
may be related to the lack of calibration frequency specified in
the procedure,
as cited in the above violation.
The licensee's
corrective
action with respect
to the above violation will be reviewed in
a future
inspection
(85-18-03).
The inspector
reviewed the results of the
EPA Interlaboratory
Comparison
program.
The licensee
conducted
a thorough review of the data
and
identified and corrected discrepancies
between their analyses
and the
results
reported
by the
EPA.
5.0
Im lementation of the Radiolo ical Environmental Monitorin
Pro
ram
a
Review of Re orts and Records
The inspector
reviewed the
1984 Annual
REMP report,
and found num-
erous inconsistencies
in the reported data.
Table XII of the Annual
REMP report contained
a list of the licensee's
reported
lower limits
of detection
(LLDs) for nineteen
isotopes
and gross
beta analysis of
air filters, water, milk, fish,
and vegetation.
A comparison of the
data in the
1984
REMP report with the
LLDs listed in Table XII indi-
cated that the licensee
did not meet the reported
LLDs in Table XII.
b.
The inspector discussed
the reported data with the licensee.
The
licensee
stated that the
LLD was met, but that Table XII did not
represent
the
LLDs met during 1984.
The
LLDs reported for sample
analyses
during 1984 were higher than those specified in Table XII of
the Annual Report.
The licensee
stated that the Table XII LLD values
were based
on old data.
The inspector stated that this data did not
represent
the actual
LLD data for 1984.
This represents
a violation
of Technical Specification 6.9. 1.3, which states
that results of all
radiological environmental
samples
taken during the report period
will be included in a summarized
and tabulated
form (85-18-04).
Table XII of the
1984 Annual
REMP report listed the
water
as
7 picocuries
per liter.
The technical
specifications
state,
in Table 4. 10-1, that the
LLD for I-131 in water will be
no greater
than
1 picocurie per liter.
The inspector discussed
with the
licensee
the difference
between
the
LLD for I-131 in water between
the technical
specifications
and the reported
value in Table XII of
the Annual
REMP report.
The licensee
stated that the
LLD require-
ments of
1 picocurie per liter of I-131 in water was not met due to
the analytical
method
used.
The inspector
stated that this was
a
violation of Technical Specification
4. 10. 1 (85-18-05).
Sam lin
Locations
and Methodolo y
The inspector
reviewed the Annual
REMP report for consistency
in
sampling locations specified in the Off-Site Dose Calculation
Manual
(ODCM) and discussed
sampling methodology with the licensee.
The
inspector
noted that the required
sampling methodology at one surface
water location, the Russell Station,
was not being implemented
in
accordance
with the technical specifications.
Instead of an aliquot
collected at intervals not exceeding
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,
the licensee
was
obtaining
a daily grab
sample of 500 milliliters.
This is
a violation
of Technical Specification
3. 16. 1. 1 (85-18-06).
Environmental
TLD Pro
ram
In Inspection
Report
No. 84-20,
the inspectors identified a concern
over the ability of the licensee'
TLDs to properly measure
and
record environmental
radiation.
The licensee
subsequently
conducted
an in-house
performance test of their environmental
TLDs ~
The results
of the performance test indicated that the licensee's
environmental
TLDs were overresponding
by 25 to 30%.
The licensee
adjusted
the
photon correction factor set point to obtain results for their
environmental
TLDs which would bring the data into better agreement.
However, the final set point for the environmental
TLDs has not been
determined.
The licensee will be participating in the Eighth International
Environmental
Dosimeter Intercomparison
Project sponsored
by
during the 1985-1986 winter season.
Item 84-20-02 will remain
open
pending the outcome of the results of the Intercomparison
and the
licensee's
in-house
performance
evaluation.
Licensee/NRC
Environmental
TLD Com arison
The U.S. Nuclear Regulatory
Commission
(NRC) Direct Radiation
Monitoring Network is operated
by the
NRC (Region I) to provide con-
tinuous measurement
of the ambient radiation levels around nuclear
power plants
(?0 sites)
throughout the United States.
Each site is
monitored by arranging approximately
30 to 50 thermoluminescent
dosimeter
(TLD) stations
in two 'concentric rings extending to about
five miles from the power plant.
The monitoring results
are published
in" NUREG-0837 quarterly.
One of the purposes
of this program is to serve
as
a basis of com-
parison with similar programs
conducted
by individual utilities which
operate
nuclear
powe~ plants.
Therefore,
a number of NRC TLDs are
co-located with each licensee's
TLD stations.
During this inspection
the monitoring results of co-located
TLDs were
compared
and the results
are listed in Table 2.
Table
1 describes
the
NRC TLD location around the Ginna site.
All NRC exposures
are normalized to
a 90-day calendar
quarter
and
reported
in units of milliroentgens
(mR),
and uncertainties
are
the total uncertainty
(random
and systematic uncertainties).
The
licensee's
TLD results
are not normalized'urthermore,
the
uncertainties
associated
with the licensee's
environmental
result,s
were unavailable
at the time of this inspection.
The
licensee
normally computes
uncertainty
on
a weekly basis,
instead
of quarterly because
the former environmental
technical
specification
required reporting the direct radiation
measurements
on
a weekly
basis.
At the time of the inspection,
the licensee
had not adjusted
their reporting methodology.
There
appears
to be generally
good agreement
between
the NRC's
data
and the licensee's
for the
1984 reporting period.
The higher
licensee
numbers
may be indicative of the overresponse
of their TLDs.
In 1983 the licensee
was using
a different TLD than is currently being
Used.
6.0
Im lementation of the Meteorolo ical Monitorin
Pro
ram
The inspector
examined
the licensee's
meteorological
monitoring system,
including the onsite meteorological
tower, the recorder charts
in the
trailer housing the meteorological
monitoring instrumentation,
and the
recorder chart in the control
room.
Discussions with various licensee
personnel,
a review of Procedure
RD-14, "Meteorological
System Survei 1-
lance,"
and
a review of logs and data indicated that the equipment
and
information are being monitored
on
a daily basis.
The inspector also
reviewed Procedures
CP-250, "Calibration and/or Maintenance of Ginna
Station Meteorological
Instrumentation,"
and CP-251, "Calibration and/or
Maintenance of Ginna Station Meteorological Transmitters."
The procedures
were well written and provided check-off sheets
for the completion of each
step in the calibration.
However,
these
two procedures
also failed to
provide calibration frequency in the procedures,
as required
by Technical Specification 6.8. 1.
These
two procedures
represent
two more examples of
Technical Specification 6.8. 1 violation (85-18-03).
7.0
Unresolved
Item
Unresolved
stems
are matters
about which more information is required in
order to ascertain
whether they are acceptable
items,
items of noncompli-
ance,
or deviations.
An unresolved
item disclosed
during this inspection
is discussed
in Paragraph
4.
8.0
Exit Interview
The inspector
met with the licensee
representatives
(denoted
in para-
graph
1) at the conclusion of the inspection at the site
on
September
6,
1985.
The inspector
summarized
the purpose
and the scope
of the inspection
and findings.
At no time during this inspection
was
written material
provided to the licensee
by the inspector.
TABLE 1
CO-LOCATION OF THE TLD STATIONS
janCeeeoion
Ginna Station
Location
~no nor i
i on
11
12
15
18
19
28
31
32
36
40
2644, 4.6 mi
245O, 3.8 mi
178op
3 4 mi
1154, 4.3
mi
884, 4.0 mi
234op
6 9 mi
Lake
Road
Bc Sa It Road
County Line Road h Woodward
Road
Route
104 (Substation
//205)
Seely
Road h Stony Lonesome
Road
Stony Lonesome
Road
8c Lake
Road
Webster
TABLE 2'N
IRONMENTAL MONITORING RESULTS
TLO STATIO
RC STAT!0
NUMB R GINNA STATION NUMBER
Monitoring Period
11/31
12/32
15/36
18/39
19/40
28/9
1st Quarter
1983
NRC
Ginna
2nd Quarter
1983
NRC
G irma
3rd Quarter
1983
NRC
Ginna
4th Quarter
1983
NRC
Ginna
1st
Qua rter 1984,NRC
Ginna
2nd Quarter
1984
NRC
Ginna
14.7
R 0.6
14
21.1 k 0.9
1
0
12.6 2 0.7
22 2
19.4
X 0.8
1
13.2
R 0.8
1
2
15.5
R 0.7
1
13.3
+ 0.6
10. 6
20.5
+ 0.9
13
1
11.6 2 0.7
1
6
18.7
+ 0.8
N
C
13.1
2 0.8
N
C
N/C
N
C
15.3
+ 0.7
14
18.9
+ 0.9
13.2
12.6
+ 0.7
1
17.9
+ 0.8
12
14.7
+ 0.8
ll 2
13.3
+ 0.6
1
15.3
+ 0.7
12
222 k 1.0
14.
12.3
+ 0.7
23.2
19.5
+ 0.8
13.7
13.4
2 0.8
11
14.0 2 0.7
1
14.1
+ 0.6
12 2
18.3
X 0.9
1
N/C
16.
17.2
+ 0.8
11. 4
13.2 4 0.8
1
12.7
+ 0.6
14
14.4 2 0.6
11.
19.7 1 0.9
12.2
12.0
X 0.7
1
18.1
2 0.8
.4
12.7 2 0.8
1 .6
12.7 2 0.6
1
.1
3rd Quarter
1984
NRC
G irma
4th Quarter
1984
NRC
Gi
na
15.1
0 0.8
21
14.5 2 0 ~ 6
1
12.2
+ 0.8
18 4
15.6
R 0.6
17
13.9
+ 0.8
1
14.8
+ 0.6
1
16.4 2 0.6
20
15.1
R 0.6
17.
14.5
X 0.8
13.8 2 0;8
1
1
=>>'-
'> "22.2
12.3
X 0.8
21
2
14.6 k 0.6
1 .8
1st Quarter
1985
NRC
Gtnna
15.6 2 0.7
1
13.9 L 0.7
14
15.7
R 0.7
1
14.8
R 0.7
1
13.9 2 0.7
1
15.1
+ 0.7
12 2
(1)
N/C (not compared
because
the
NRC or the licensee's
data were not available
due to missing or dainaged
dosimeters).
I
i
t