ML17261A933
| ML17261A933 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/23/1990 |
| From: | Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A932 | List: |
| References | |
| 50-244-90-01, 50-244-90-1, NUDOCS 9002060362 | |
| Download: ML17261A933 (12) | |
See also: IR 05000244/1990001
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244 90-01
Docket No.
50-244
License
No.
Category
Licensee:
Rochester
Gas
and Electric Cor oration
as
venue
oc es er
ew
or
Facility Name:
Ginna Nuclear
Power Plant
Inspection At:
Ontario
Inspection
Conducted:
Januar
8 -
12
1990
7
Inspector: &
onne
a
sa
>on
pecia
ss
a
e
Approved by:/
ascia
,
>e
,
ac
s
res
a ia
>on
Protection Section
- c'0
a
Ins ection Summar:
Ins ection conducted
Januar
8 -
12
1990
Ins ection
e or
o.
Areas
Ins ected:
This inspection
was
a routine unannounced
inspection of the
licensee
s radiological controls
program
and the licensee's
preparations
for the next refueling outage.
Areas reviewed include: Organization
and
Staffing, Training, Audits and Appraisals,
E'xternal
Exposure Controls,
and
Results:
Within the scope of this inspection
no violations were identified.
1.0-
Persons
Contacted
Licensee
Personnel
- S. Adams
- R. Carroll
- D. Filkins
W.
Goodman
- A. Herman
- A. Jones
- F. Mis
- B. Quinn
- F. Robare
S. Spector
- R. Watts
- S. Warren
- J. Widay
DETAILS
Technical
Manager
Ginna Training Manager
Manager,
HP and Chemistry
Health Physics
Foreman
Health Physicist
Corrective Actions Coordinator
Health Physicist
Corporate
Health Physicist
Quality Control Engineering Assistant
Plant Manager
Director, Corporate Radiation Protection
Health Physicist
Superintendent,
Ginna Production
1.2
NRC Personnel
C. Marschall
- N. Perry
Senior Resident
Inspector,
Ginna
Resident
Inspector,
Ginna
2.0
3.0
- Attended the exit meeting
on January
12,
1990.
Other licensee
personnel
were also contacted
during the course of this
inspection.
~Por ose
~ The purpose of this routine,
unannounced
inspection
was to review the
licensee's
radiation protection
program
and the licensee's
preparations
for
the next refueling outage.. Areas reviewed included organization
and
staffing, audits
and appraisals,
training, external
exposure controls,
and
Or anization
and Staffin
The inspector
reviewed the 'Health Physics
(HP)
and Chemistry Organization
Chart
and noted that the licensee's
staffing level remained
constant
in
this area for the past year.
During the last refueling outage the
NRC noted
instances
where the licensee
experienced
a shortage of permanent
technicians
(HPTs).
The
HP and Chemistry Manager stated that they are
attempting to resolve this matter
and the
HP and Chemistry Department
has
corporate
approval to hire eight additional
permanent
HPTs. Although these
additional
HPTs will not be hired and qualified in time for the next
refueling outage, the licensee
has partially addvesaK this shortage
Ry
augmenting them staff with 10 contractor HETs who have been on site suxe
the last refueling outage.
%he reorganization has also created five Lead
HET positions.
%he licensee anticipates fillingthese positions as new
permanent
HETs became qualified.
'lhe licensee recently reorganized the pr~ areas of ~nsibility for
several of the HP Supervisors.
She HP Supzvxsor who previously oversaw the
dosimetry and instrumentation functions m now responsible for the
licensee's
dosimetry and AIAEQ, pmgrarns.
%he licensee stated that this
reorganization will allow for better oversight of the AIARAprogram. Under
the previous organization,
one HP Supervisor was ~nsible for both AItQQ.
and radwaste.
'Ihe licensee detexmirmd that the ~m of these two areas
was
too diverse and too extensive for one supervisor.
In addition, the licensee has made an improvement in the staffing of the
AIARA gD:mp by assigning two HETs, one a long-texm contractor, to work for
the AIARASupervisor.
Lhis was partially in response to a NRC concern that
the licensee did not have personnel available or ~nsible for ensuring
that AIARA recommerx3ations
and AIt6% requirements
were implemented in the
field. lhe licensee stated that during the outage these two HETs will
fulfillthis function.
An additional HP SuEx~ision position,
HP Operations,
was also created by
the reorganization.
'Ihis position, which currently is not staffed, will be
responsible for supervising the HP Foreman and the HPTs. 'Ihe licensee
stated that they wall st-~ fooking for an individual to fillthis position
this summer.
The inspector discussed the anticipated outage staffing levels of
contractor ~ with the HP and Chemistry Manager.
the licensee is planning
on staffing the HP Department at the same level as during last year'
refueling outage.
'Ihe licensee anticipates that, since the work scope for
this outage is less than last year', the staffing level will be adequate.
In response to a previous
NRC concern regarding the lack of technical
kncarledge of contractor HPTs and in an effort to ensure that well qualified
HETs are hired, the licensee stated that they are rec{uiring a high
percentage
(80o) of the contractor HETs to be qualified in accordance with
ANSI/ANS-3.1.- 'Xhis is more restrictive than the qualifications ~red by
the licensee's
Technical Specifications.
During the last refueling outage the NRC identified a concern regarding the
lack of in-field ~wisoxy oversight of work activities in the contmlled
areas of the plant. Administratively the licensee has not addressed this
co~. We licensee stated that management
has etophasized the need for
increased in-field oversight to the HP Supervisors.
'Ihe effectiveness of
the licensee's
resolution of this concern will be reviewed during a future
ingestion.
4.0
Audits and
raisals
%he licensee utilizes a Radiological Incident Report
(RIR) to record such
incidents as personnel conMninations, violations of HP procedures,
unusual
radiological conditions and loss of dosimetry.
%he inspector reviewed
several
RIRs to determine the adequacy of the licensee's chive actions
for such incidents.
The licensee's corrective actions for the RIRs reviewed
were adequate.
During a previous inspection it was noted that the licensee
did not have a mechanism to track RIRs as it was discovered that chive
actions for several RIRs were not documented.
In response to this, a
Chive Actions Coordinator now tracks significant RIRs to ensure that
corrective actions are taken by the responsible supexvisor.
The in.~~r
noted that the licensee bas implemented a practice of having the Chive
Actions Coordirmtor also track concerns
wctu.ch are identified in NRC
inspection reports. This is a good initiative.
The in@~or reviewed the 1989 Quality Assurance Audits of the radiation
protection program. Audit findings reflected that a tho~ audit of the
radiation protection program had been conducted.
Although the licensee's
response to audit findings was adequate,
the timeliness of response to
aucLLt findings needs
improvement.
For example, the ~nse to audit report
89-29: JB was almost three months late.
The licensee stated that they recently changed the manner in which they
conduct Quality Assurance Audits of the rachation protection program. In
the past, the licensee conducted three audits, typically with two auditors,
of the radiation protection program each year.
The licensee nor plans on
conducting one annual comprehensive audit of the radiation protection
procp~m with a team of five auditors.
'Ihe licensee plans on beqinning a
program with other utilities to have individuals free other utilities
participate in their audit. Licensee personnel,
in turn, willparticipate
m audits of other utilities. Having personnel with ~xrience at other
utilities participate in the audits and having licensee personnel review
other radiation protection programs should strengthen the licensee's
program ~
'Ihe licensee also recently implemented a Quality Assurance Surveillance
E~3ram which includes surveillances of the radiation protection procpmn.
The licensee stated that they plan on conducting five surveillances of the
radiation protection program in 1990.
In addition to these audits,
a Quality Assurance Specialist,
who works for
the HP and Chemistry Manager, routinely reviews such records as counting
instrument control charts and the remits of chen6stry analyses.
'%he
inspector reviewed several
HP and Chemistry Quality Control Review records
and noted that thorough reviews were routinely conducted.
5
5.0
6.0
TXB]IJQIlg
'lhe inspector discussed the training department's
preparations for the
outage with the trainexs who conduct the General Employee Traininq and
Radiation Protection Training. 'Ihe training staff s plans, which include
aucpaenting the training staff and inn~sing the frequem( of training
sessions, appe~ to be adequate to in-process the anticipated number of
autage workers in a timely manner.
'Ihe inspector discussed with the individual resgensible for providing HP
training for the contractor HETs the ugcpades
which the training staff
recently developed for training contractor HPIh. Ihe licensee develaped
a
training pre@ram for contractor HFTs which focuses
on specific job caverage
guidelines for three adams:
work, refueling actxvities,
Auxiliary Building work. Ihese guidelines were developed by using feedback
fram experienced
permanent staff HPZs. Ihe guidelines address potential
problem areas
and specify acceptable job coverage practices.
A previous
NRC inspection identified weaknesses
in the licensee's training
of Op~tars
and Auxiliary Operators. It was noted as a wealmess that the
operators
were not being well trained to be self monitor qualified in the
~~r reviewed lesson plan NRC42c "Self Monitoring Using the Alnor
Rad-85, the Victoreen 450 B and the Eberline RO-2A" and nated that the
lesson plan con~~ the noted weaknesses.
Ihe inspector reviewed class
attendance
sheets
and verified that
the Operators
and qualified Auxiliary
tors had received the training. Ihe licensee stated that this training
w3.11 continue to be provided annually.
Easel
e Controls
During several tours of the station the inspector noted that~ were
properly posted,
barricaded or locked as required.
Ihe inspector reviewed
several completed Radiation Work~t packages
and noted that appropriate
radiological surveys had been made for the work activities as required.
'Ihe inspector reviewed the licensee's
National Voluntary Laboratory
Accreditation Program
(NVIZQ?) certification for their dosimetry processing.
'Ihe licensee uses two types of thermoluaunescent
dosimeters
(TZDs) to
nanitor personnel
exposures.
Ihe TID routinely worn by station l~nnel is
NVIAP accredited in categories I through VIII. Ihe other TID issued to
individuals is NVI~ accredited in categories I through VII. Individuals
wear both TLDs when working in potential neutron radiation fields. Using
the ~ts of both TIZs the licensee is able to quantify pexsonnel neutron
Kgxsure
'Ihe inspector noted that the licensee routinely assigned
whole body
exposures to individuals based
on element four of the TZD. 'Ihis element is
I
positioned under 1000 ng/cm2 of absorber.
NRC Form-5 states that unless the
lenses of the eyes are shielded with eye shields at least 700 mg/cm2 thick,
the dose recorded as whole body dose should include the dose delivered
throu'
tissue equivalent absorber having a thidmess of 300 mg/cm2.
'Xhe
licensee requu~ safety glasses to be worn in all the controlled areas of
the plant.
%he licensee's
Radiation Control Manual states that the safety
glasses
worn by individuals have a thickness of at least 700 mg/cm2.
However, when the inspector asked for verification of the thickness of the
safety glasses
worn by station personnel,
the licensee discovered that the
safety glasses
were only 300 to 380 ng/cm2.
%he inspector asked the licensee to verify that they properly evaluated the
dose to the lenses of the eyes,
which is considered
a whole body exposure,
from high enex~ beta emittms such as Sr-90/Y-90.
%he licensee provided
the inspector with their evaluation which included the following:
'Ihe waste stream analysis
sheared that the percentage of high energy
beta emitters in the waste streams
was very low.
An analysis of the beta dose rates,
through different thidmess of
absorber, in the steam generator channel head showed that the beta
dose rate through 1000 mg/cm2 of absorber
and the beta dose rate to
the lenses of the eyes of individuals inside the channel head were
essentially the same.
'Ihe licensee provided the inspector with several TID~ts and
individual exposure reports which showed that the Dosimetry Supervisor
routinely analyzed the TID remits and assigned
a whole body dose
based
on TID element thi~ (300 nq/cm2 of absorber) if the element
three reading was significantly?u.gher than the element four reading.
Based on this data, it appeal that the licensee
was adequately evaluating
individual's whole body exposures.
'The following areas for improvement were
discussed with the licensee:
~
'Ihe licensee's
Radiation Control Manual should be updated to reflect
the proI~ thickness of the safety gl~ worn and more attention
needs to be placed on evaluating the radiological impact of equipment
or procedural
changes.
%he licensee stated that they will routinely evaluate their isotopic
analyses to ensure that the concentrations of high energy beta
emitters remains sufficiently lear.
lhe licensee stated that the dosimetry procedures will be updated to
reflect the criteria the Dosimetry Supervisor uses to deternune
whether to use the element three reading of the TID to assign whole
body doses.
The inspector noted a
in the manner which scxne'individuals wore
their personnel dosimetry whale zn the controlled area.
awhile the majority
of irxb.viduals wore their dosimetry in the upper chest area in the front of
their bodies the inspector observed several individuals, includirq HPXs,
wearing their dosimetxy hanging off the bottom of their belts, st~ and
sweaters.
In same instances the dosimetry was positioned over the side of
the individual's leg. %his practice is not consistent with the guidance
given in both the licensee's
Radiation Control Manual and in Procedure
HP-4.1 "Controlled Area Entxy". Both of these references state that
dosimetry should be in the area betmmi the waist and the shoulders.
%he
ixxLividual who conducts the General Employee Radiation Pmtection Training
stated that the training specifies that dosimetry should be worn in the
upper chest area and in the front of the body.
%he HP and Chanistxy Manager
stated that they would reemphasize
the proper placement of dosimetry to
individuals. 'Qu.s item will be reviewed during a future inspection.
7. 0
AItQQ.
the inspector reviewed several
AIARAreviews which had been completed for
work activities during the 1989 refueling outage.
%he AIAEKreviews
irdicated that an adequate
AIAIQ. review had been conducted for the major
outage work activities.
%he in~mtor reviewed several corporate,and plant
AIAfQ, Cmmu.ttee meeting minutes and noted that thorough AIARA reviews had
been completed for significant activities.
'Ihe licensee
exceeded their 1989 AIARAgoal of 550 man-rem by approximately
60 man-rem.
%he inspector reviewed several AIKQ. estimates for the 1989
outage arxl noted that the majority of the exposure which exceeded the AIARA
goal was due to steam generator
work. Several of the newly installed tube
plugs in the B steam generator were found to be defective and had to be
removed and replaced.
%his resulted in an additional 20 man-rem of
exposure
During the 1989 outage the licensee sleeved several of the perimeter tubes
in the steam generator.
In the past,
when recpdred,
the licensee plugged
rather than sleeved perimeter tubes.
Both the lack of experience
xn
sleeving perimeter tubes and the number of tubes which had to be sleeved
vmQted m this activity exceecling the AIARA estimate by 17 man-rem.
%his
irxlicates that improvements still can be made in,the manner in which AIARA
estimates
are derived for'nonroutine work activities.
'lhe AIARARq~isor stated that he routinely atterxls the planning meetings
for Engineering Design Changes
(EDC) arxl in that way he is kept informed of
the EDCs planned for the up:xaning outage. At the time of the inspection the
AIARA group bad a list of planned
EDCs and were in the process of
conducting the AIARA reviews.
%he licensee is developing procahuas to recure
AIAfQ, prejob briefings for
all work activities that recpure an AItQQ, review. 'these briefings should be
0
helpful in reducing erasures
by ensuring that all aspects of the work are
thoroucPQ.y planned. ~ is a good initiative.
'Ihe licensee has set the 1990 ALtQQ, goal at 523 man-rem.
%his goal appears
to be appropriate based
on the planned work scope for the upcoming outage.
Major outage tasks include installation of mirror insulation on a reactor
coolant pump and pulling a tube out of one of the steam generators.
%he
licensee estimates that these two t-eks alone will account for 135 man-rem.
%he inspector met with licensee representatives,
denoted in Section 1.0 of
the report,
on January
12, 1990.
'lhe inspector sunmarized the purpose of,
scope and findings of the inspection.
'Ihe inspector noted that the licensee
had not been ~nsive to an industrial safety concexn which was
'dentified
during NRC inspection 50-244/89-23.
%he licensee
had not
addressed
the concern that they allow individuals to eat and drink in an
area where toxic chemicals are used, the chemistry laboratory.
%his is not
a generally accepted industrial safety practice.
lhe licensee stated that
they would have their Safety Department review this concern.