ML17261B066
| ML17261B066 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/25/1990 |
| From: | Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261B063 | List: |
| References | |
| 50-244-90-07, 50-244-90-7, NUDOCS 9005080155 | |
| Download: ML17261B066 (7) | |
See also: IR 05000244/1990007
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244 90-07
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:
A ril 16 - 20
1990
I
Inspector:
onne
,
a ia ion
pecia is
a e
Approved by:~
~
ascia
,
ie
,
aci i ies
a ia ion
Protection Section
0/a~/ps
a
e
Ins ection Summar:
Ins ection conducted
A ril 16 - 20
1990
Ins ection
e or
o.
Areas Ins ected:
This inspection
was
a routine unannounced
inspection of the
imp emen ation of the licensee's
radiological controls program during the
current refueling outage.
Areas reviewed included: Organization
and
Staffing,
and External
and Internal
Exposure Controls.
The inspector also
provide6 input regarding
ALARA and the integration of radiological controls
into the maintenance
process
to the
NRC Maintenance
Team which was
concurrently conducting
NRC Maintenance
Team Inspection
No. 50-244/90-80.
Results:
Mithin the scope of this inspection
one violation was identified. The
vsolation involved
a fai1ure to set
an administrative
exposure limit in
accordance
with licensee
procedures.
9005080155
900427.
ADOC~ 05000244
0
'1. 0
1.2
Persons
Contacted
Licensee
Personnel
- D. Filion
- D. Filkins
- A. Gillet
W.
Goodman
- P. Lewis
- R. Mecredy
F. Mis
- J. Quigley
B. Quinn
- M. Saporito
- E. Selbig
- R. Smith
- J. Smith
S. Spector
- J. St. Martin
- K. Wachter
- R. Watts
- J. Widay
NRC Personnel
- J. Carrasco
- J. Jang
~A. Johnson
- H. Kaplan
- T. Moslak
- T. Polich
- N. Perry
- R. Wessman
DETAILS
Radiochemist.
Manager,
Health Physics
and Chemistry
Erosion/Corrosion
Coordinator
Health Physics
Foreman
Nondestructive
Examination Outage Coordinator
Division Manager,
Nuclear Production
Health Physicist
Quality Services
Coordinator
Corporate Health Physicist
Supervisor,
Materials Engineering
Quality Control, Health Physics
and Chemistry
Senior Vice President,
Engineering
and Production
Manager, Materials Engineering
Plant Manager
Corrective Actions Coordinator
Eddy Current Coordinator
Director, Corporate Radiation Protection
'uperintendent,
Ginna Production
Reactor
Engineer
Region I
Radiation Specia/ist,
Region I
Office of Nuclear Reactor Regulation
Reactor Engineer,
Region I
Resident
Inspector,
Three Mile Island
Office of Nuclear Reactor Regulation
Resident
Inspector,
Ginna
Office of Nuclear Reactor
Regulation
2.0
- Attended the exit meeting
on April 20,
1990.
Other licensee
personnel
were also contacted
during the course of this
inspection.
~Pur
ese
The purpose of this routine,
unannounced
inspection
was to review the
implementation of the licensee's
radiological controls program during the
current refueling outage.
Areas reviewed included organization
and
staffing and external
and internal
exposure controls.
The inspector also
providel input regarding
ALARA and the integration of radiological controls
into the maintenance
process
to the
NRC Maintenance
Team which was
concurrently conducting
NRC Maintenance
Team Inspection
No. 50-244/90-80.
3.0
4.0
Or anization
and Staffin
The inspector reviewed the adequacy of the staffing levels of both
permanent
and contractor Radiation Protection Technicians
(RPTs}. The
inspector discussed
the staffing levels with cognizant
personnel
and
observed
several
radiation protection
(RP) work briefings
and
RPT job
coverage of ongoing work. In general
the staffing level of RPTs appeared
to
be adequate
to provide coverage for those activities observed
by the
inspector.
The licensee
has
made
improvements in the staffing of the ALARA group
compared to the previous outage
by having
a
RPT dedicated full time to
ALARA planning
and having another
RPT dedicate
approximately
75% of his
time to ALARA planning.
Discussions with individuals from the
ALARA group
and review of Radiation
Work Permit
(RWP)
and Special
Work Permit
(SWP)
entry logs indicated that additional
outage staffing of ALARA RPTs to
ensure that
ALARA considerations
are
made in the field would be helpful.
The ALARA Supervisor stated that tentative staffing plans for the next
refueling outage include hiring additional
RPTs for this purpose.
Shortly before the current outage
two positions in the licensee's
management
organization
became
vacant.
These positions
included the
Dosimetry Foreman
and the Respiratory Protection
and Internal Dosimetry
Health Physicist.
The loss of these
two individuals has placed
an extra
workload on the remaining two Health Physicists
and the Health Physics
(HP)
and Chemistry Manager
and
may have contributed to some of the concerns
noted in the Section 4.0 of this report.
The licensee
plans
on filling the
position of Respiratory Protection
and Internal Dosimetry Health Physicist
as
soon
as possible.
The licensee is evaluating restructuring the
responsibilities of the Dosimetry Foreman
and it is uncertain whether this
position will be filled. The licensee
plans
on adding the position of
Operations
Health Physicist to enhance
supervisory oversight of the
RPTs.
External
and Internal
Ex osure Controls
The inspector conducted
several
tours throughout the controlled areas of
the facility. The inspector verified that areas
were properly posted
. barricaded,
or locked
as required.
The inspector did note one area where
the area postinq could have
been better situated.
The inspector noted that
the High Radiation Area posting
on top of the pressurizer
cubicle had
been
moved to the side
and was not readily visible to individuals entering the
ressurizer
cubicle from the top.
The
RPT on the refueling floor stated
hat the posting
had previously been positioned over the entrance
but,
apparently,
someone
had moved the posting.
The inspector noted that the licensee
had recently identified two instances
where High Radiation Areas,
which were required
by procedure to be locked,
were found unlocked.
The licensee
had not completed their analysis of the
the root causes
or appropriate corrective actions to prevent recurrence.
This item will be reviewed during a future inspection.
The inspector reviewed the dosimetry records of selected individuals and
determined that
NRC Form-4s
had satisfactorily been completed for the
individuals prior to allowing them to exceed
1250
mRem per calendar
quarter.
While reviewing these
records the inspector noted that
on March 24,
1990
an
individual with 1672
mRem of occupational
exposure
from other licensed
facilities for the first calendar quarter of 1990 was given
an
administrative'ose limit of 1973
mRem for the first calendar quarter of
1990. This resulted
in the individual's exposure
being administratively
limited to 3645
mRem for the first calendar quarter of 1990.
The inspector
verified that the individual received
a dose of only 144
mRem during the
eriod of March 24 to 31
1990 and therefore the individual's total dose of
816
mRem for the first calendar quarter did not exceed the regulatory
limit of 3000
mRem per calendar quarter.
The inspector discussed
this matter with the Dosimetry Clerk and the Health
Physicist
who was supervisinq
the Dosimetry Clerks. Apparently,
an exposure
received at
a previous facility during the first calendar quarter of 1990
had been overlooked
when the individual's administrative
dose limit was
set.
The licensee's
oversight of this area
was deficient because
the
program did not require supervisory
or any other type of review of
~
~
~
~
ersonnel
exposure
records to ensure that correct administrative
dose
imits were assigned.
In this instance it was fortuitous that
an
individual's quarterly dose
had not exceeded
the regulatory limit.
The inspector reviewed the licensee's
dosimetry procedures
and noted that
procedure
HP-1.2,
"External
Exposure Limits", requires in Section 6.2.4.2
that personnel
having
a completed
Form NRC-4 shall
be administratively
limited to 2000
mRem per calendar quarter.
The licensee's
assigning
an
incorrect administrative
dose limit of 3645
mRem per calendar quarter to
an individual is as
an apparent violation of Technical Specification 6. 11,
Radiation Protection
Program,
which requires
'that radiation control
procedures
shall
be adhered to for all operations
involving personnel
radiation exposure.
(50-244/90-07-01)
The inspector observed
the
RP coverage for eddy current testing
and tube
plugging on the steam generators.
While contractor
coverage for these activities, the licensee
appointed
permanent
as
coordinators for these activities.
The inspector did note
some discrepancy
between
RPTs regarding the timing of individuals who insert their arms
inside the steam generator
manway.
One
RPT stated that he would time
individuals whenever .any portion of an individual was inserted into the
manway entrance.
Another
RPT stated that he only timed individuals when
they inserted their arm beyond the elbow into the manway. Another RPT
stated that timing was only required
when individuals were working for more
than five minutes with their arm inside the manway.
5
5.0
The inspector also observed that calculated
stay time information
for
whole body and extremity exposures
was not available at the control points
for both steam generators.
In addition, the licensee
was not utilizing
alarming or- remote reading dosimeters
to monitor the accumulation of dose
to the individuals. In light of the fact that the licensee
was controlling
individual exposures
based primarily on survey data
and calculated
stay
times it appeared
that more emphasis
needed to be placed
on determining
stay times
and timing entries for both whole body and extremity exposures.
The licensee
stated that they would evaluate their requirements
for timing
arm entries into the steam generators
and that they were evaluating the
purchase of remote reading dosimeters for steam generator
work.
The inspector
reviewed the licensee's
program to determine the air quality
of the supplied breathing air for the containment
and auxiliary building
constant flow breathing air system.
The licensee
has procedures
to ensure
that the breathing air system air quality meets or exceeds
the Compressed
Gas Association requirements for Grade
D air. The .inspector verified that
the licensee
had followed these
procedures
prior to initiating the supplied
air system for the steam generator
workers.
The inspector reviewed the licensee's
method of trackinq individual
exposures
to concentrations
of airborne radioactivity, i.e. the number of
hours individuals are exposed to the maximum permissible concentration
(MPC-hours). While the licensee
has
made
improvements
in this area over the
~
~
ast year,
a further improvement
needs to be made in this area.
Currently
he licensee prints out
a weekly report of the MPC-hour exposures for all
individuals.
These reports total the MPC-hour exposures
from the beginning
of the previous
week through the end of the previous
week, i.e.
Sunday
through Saturday.
These reports
are
used to ensure
the licensee
takes
corrective actions for individual exposures
greater
than
40 MPC-hours in
any seven consecutive
days,
as required
by 10 CFR 20. 103(b)(2).
The inspector
noted that
an individual could receive
a MPC-hour exposure
late in the first week and another
MPC-hour exposure early in the second
week with the total exposure
bein~ greater than
40 MPC-hours in seven
consecutive
days
and the licensee
s program would not identify the need to
take corrective actions.
The inspector verified that no individual had
been
exposed to more than
40 MPC-hours in any seven consecutive
days.
The
licensee
stated that they would revise the method of tracking MPC-hour
exposures
to address this discrepancy.
~Erat
N tI
The inspector
met with licensee representatives,
denoted in Section
1.0 of
the report,
on April 20,
1990.
The inspector
summarized
the purpose,
scope
and findings of the inspection.