ML20037D358

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Forwards IE Health Physics Appraisal Rept 50-244/80-16 on 801207-19 & Significant Appraisal Findings.No Noncompliance Noted
ML20037D358
Person / Time
Site: Ginna 
Issue date: 06/15/1981
From: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
ROCHESTER GAS & ELECTRIC CORP.
Shared Package
ML20037D359 List:
References
NUDOCS 8107100118
Download: ML20037D358 (4)


See also: IR 05000244/1980016

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UNITED STATES

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Docket No. 50-244

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Rochester Gas and Electric Corporation

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ATTN: Mr. J. E. Maier

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Vice President

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Electric and Steam Production

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Rochester, New York 14604

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Gentlemen:

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Subject:

Health Physics Appraisal

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The NRC has identified a need for licensees to strengthen the health physics

programs at nuclear power plants and has undertaken a significant effort to

assure that action is taken in this regard. As a first step in this effort,

the Office of Inspection and Enforcement is conducting special team appraisals

of the health physics programs, including the health physics aspects of radio-

active waste management and cnsite emergency preparedness, at all operating

power reactor sites.

The objectives of these appraisals are to evaluate the

overall adequacy and effectiveness of the total health physics program at each

site and to identify areas of weakness that need to be strengthened. We will

use the findings from these appraisals as a basis not only for requesting

individual licensee action to correct deficiencies and effect improvements but

also for effecting improvements in NRC requirements and guidance.

This effort

was identified to you in a letter dated January 22, 1980, from Mr. Victor

Stello, Jr., Director, NRC Office of Inspection and Enforcement.

During the period of December 7-19, 1980, the NRC conducted the special appraisal

of the health physics program at the Ginna Nuclear Generating Station. Areas

examined during this appraisal are described in the enclosed report (50-244/80-16).

Within these areas, the appraisal team reviewed selected pro edures and representa-

tive records, observed work practices, and interviewed personnel.

It is

requested that you carefully review the findings of this report for consideration

in effecting improvements to your health physics program.

The portion of the

appraisal pertaining to emergency planning and preparction will be transmitted

separately at a later date.

The findings of the appraisal at Ginna indicate that while your radiation

protection program is generally acceptable in most areas, there are some

portions of the program that require improvement to be acceptable.

Particular

findings are discussed in detail in Appendix A, "Significant Appraisal Findings."

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.15 JUN 1981

Rochester Gas and Electric Corporation 2

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We recognize that an explicit regulatory requirement pertaining to each significant

weakness identified in Appendix A may not currently exist.

However, to determine

whether adequate protection will be provided for the heath and safety of

workers and the public, you are requested to submit a written statement within

twenty (20) days of your receipt of this letter, describing your corrective

action for each significant weakness identified in Appendix A, including:

(1)

steps which have been taken; (2) steps which will be taken; and (3) a schedule

for completion of action.

This request is made pursuant to Section 50.54(f)

of Part 50, Title 10, Code of Federal Regulations.

No items of noncompliance were identifed within the scope of this appraisal.

You should be aware that the next step in the NRC effort to strengthen health

physics programs at nuclear power plant's will be the imposition of a requirement

by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop,

submit to the NRC for approval, and implement a Radiation Protection Plan.

Each licensee will be expected to include in the Radiation Protection Plan

sufficient measures to provide lasting corrective action for significant

weaknesses identified during the special appraisal of the current health

physics program.

Guidance for the development of this plan will incorporate

pertinent findings from all special appraisals and will be issued by NRR later

this year.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federa Regulations, a copy of this letter and the enclosures

will be placed in the NRC's Public Document Room.

If this material contains

any information that you believe to be proprietary, it i.s necessary that you

make a written application within 20 days to this office to withhold such

information from public disclosure. Any such application must be accompanieo

by an affidavit executed by the owner of the information, which identifies the

document or part sought to be withheld, and which contains a statement of

reasons which addresses with specificity the items which will be considered by

the Commission as listed in subparagraph (B)(4) of Section 2.790. The information

sought to be withheld shall be incorporated as far as possible into a separate

part of the affidavit.

If we do not hear from you in this regard within the

specified period, this letter and the enclosures will be placed in the Public

Document Room.

Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Sincerely,

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W

Boy e H. Grier

Director

Enclosures:

1.

Appendix A, Significant Appraisal Findings

2.

Office of Inspection and Enforcement Inspection Report Number

50-244/80-16

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,15 JUN 1981

Rochester Gas and. Electric Corporation 3

cc w/encls:

B. A. Snow, Plant Superintendent

J. Bodine, QC Engineer

Harry H. Voigt, Esquire

J. T. St. Martin, Technical Assistant,

Operations Assessment Engineer

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APPENDIX A

Significant Appraisal Findings

In the course of this appraisal, the following items were identified as needing

improvement in order to achieve an acceptable program.

1.

An accurate description of the Radiation Protection organization was not

developed, established and maintained sufficient to define the organiza-

personnel involved (porting chains or functional descripions of the

tional hierarchy, reincluding responsibilities and authorities).

Adminis-

trative Procedures have not been revised to reflect the current arrangement

of the Chemistry and Health Physics organization, nor have Job Descriptions

been established that accurately represent the positions in the organiza-

tion as it currently exists, including that of Corporate Health Physicist.

(Section1.0)

2.

The quality assurance program implemented for the vendor-supplied film

badge devices is not implemented sufficiently to assure that the device

provides an accurate estimate of personnel exposures.

(Section 3.1)

3.

There are no adequate procedures formally established, maintained and

implemented that permit the evaluation of uptakes of radioactivity from

air samrles or bicassay results.

(Section 3.2)

4.

There are nc procedures established, implemented or maintained that

discuss the process of collecting and analyzing urine and fecal material

for evaluating personnel exposure to radioactivity. (Section 3.2)

5.

There is no independent verification of the whole body counter performed

sufficient to assure that the instrument is calibrated and functioning

properly.

(Section 3.2)

6.

Personnel are not provided sufficient opportunity to physically acquaint

themselves with certain types of respiratory protective devices, particularly

self-contained breathing apparatus.

Inordinate reliance is placed upon

information provided by videotape with little effort directed to assure

that personnel are proficient in the use of the equipment.

(Section 3.2.1)

7.

The calibration program and procedures for portable survey instruments and

installed area monitors need to be revised to meet the recommendations of

ANSI N323, " Radiation Protection Instrumentation Test and Calibration."

Specifically, you need to develop operational source checks for portable

survey instruments and portable area monitors as recommended in ANSI

N323.

(Section 3.3)

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