ML20038C850
| ML20038C850 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/20/1981 |
| From: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20038C831 | List: |
| References | |
| NUDOCS 8112140193 | |
| Download: ML20038C850 (6) | |
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snn ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE, ROCHESTER, N.Y.14649 JOHN E. uAfER VICC P ri t s l :, t N T a=Eacocena 546 2700 August 20, 1981 U.S.
Nuclear Regulatory Comnission Office of Inspection and Enforcement Attention:
Mr. Soyce H. Grier Director, Region I 631 Park Avenue King of Prussia, PA 19406
SUBJECT:
Response to Significant Findings, Appendix A, Health Physics Appraisal Inspection Report 80-16.
Dear Mr. Grier:
This letter is a follow-up response to the NRC Health Physics Appraisal Inspection Report 80-16, received on June 18, 1981.
In this response more details are given to indicate our actions subsequent to the significant findings noted in Appendix "A"
of the Inspection Report.
Sincerely, J
n E. Maier kk KO O
L J
ATTACHMElff A RG&E Response to Significant Appraisal Findings Inspection Report 30-16, Health Phyeics Appraisal R.E. Ginna Nuclear Power Plant ITEM 1:
NRC Finding:
An accurate description of the Radiation Protection Organization was not developed, established and maintained sufficient to define the organizational hierarchy, reporting chains or functional descriptions of the personnel involved (including responsiblilities and authorities).
Adminisbrative 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 organization as it currently exists, including that of Corporate Health Physicist. (Section 1.0)
RG&E Response:
As in any organizational structure, the utilization of the personnel available should be matched to the duties and responsibilities they are best suited to.
This makes a rigid structure sanewhat difficult.
In the structure that was presented at the time of the inspection the term Health Physicist was not utilized in the block diagram presented.
The three positions alluded to in the inspection report though were being filled by qualified Health Physicists. 'Ihis title could easily be added to the description although it would not really add any significant meaning to the position title.
Since the inspection unfortunately one of the Health Physicist has lef t this Company for another job. Until he is replaced and the replacement is trained the responsibilities of ALARA and respiratory protection coordination will have to be shared among the remainder of the staff.
The structure as it was presented seems to be workable so we most probably will reflect this in the position descriptions being developed on an overall company basis. The position description for the Health Physics and Chemistry organization should be completed by 6/1/82.
During the interim, especially with the changes which are now in effect, we will keep the Health Physics section informed of responsibilities and reporting chains through informal meetings held weekly during notinal operation.
In the body of the appraisal the inspectors indicated concern over the lack of authority to stop a job in the case cf any radiological condition compromising the safety of the workers on a job. Management has always backed the Health Physics section in any case of work stop-page when any of the Health Physics section felt there was a safety problem. This will be and has been emphasized to the section members.
Management does reserve the right after due consideration to restart the job if they determine that the job is necessary and can be perfomed safely.
ITB4 2:
NRC Finding:
The quality assurance program implemented for the vendor-supplied film badge is not implemented sufficiently to assure that the device provides an accurate estimate of personnel exposure.
(Section 3.1)
RGLE Response:
Since the audit we have instituted HP-1.7 " Film Badge Accuracy Test".
This procedure directs that minimun of 12 badges be exposed at four exposure levels (500, 1000, 1500 and 2000 millirem). Starting in September 1981, we will increase the number of badges exposed to four at each exposum level so if a discrepancy occurs, an evaluation can be perfomed using ANSI N-13.7 As of August,1981 a mininum of 12 films per month are being exposed on a natural uranium slab to check the films' beta response. This check will also be documented by procedure HP-1.7 The results are forwarded to a Health Physicist for review. If the badges do not meet the acceptance criteria, further evaluation will be perfomed using ANSI N-13 7 Our current film badge supplier has sutnitted to and met all existing perfomance criteria. In particular, they sutnitted to the University of Michigan study (NUREG/CR-1063) and were fourd to be acceptable as the standard existed for beta and gmra cbsimetry for the energies nonrally encountered in a facility of our type.
In addition, film badge results are compared with results fecm two other dosimeters involving completely different rmthods of exposure detemination. Systematic errors in any of the dosimeters will be apparent when perfoming HP-1.4 (Dosimeter Discrepency Evaluations).
This system has the advantage of including all variables encountered in the field which may in some cases be superior to evaluations using standard sources.
ITS4 3:
NRC Finding:
There are no adequate procedures romally established, maintained and implemented that pemit the evaluation of uptakes of radioactivity fem air samples or bioassay results.
(Section 3.2)
RG&E Response:
No chang from the July 8, 1981 response. Procedures will be sulnitted to the Plant Operations Review Committee by 9/10/81.
ITE4 4:
NRC Finding:
There are no procedures, implemented or maintained that discuss the process of collectirig and analyzing urine and fecal material for evaluating personnel exposure to radioactivity.
(Section 3.2)
RG&E Response:
Formal procedures am being written for the collection, handling, and transportation of urine and feces samples. The procedures are being written to incorporate the reconnendations of ANSI N-343 as appropriate.
Analysis of the urine and reces samples can be perfomed using our standard counting procedures adjusting sample size and geometry for different sample activities.
Althotyf1 we do not nomally perfonn these analyses, at least twice in the past we have analyzed urine and feces. In both cases, the information was used to help evaluate internal contamination cases.
As indicated in the telecon to Mr. John Wite, of the NRC on 8/S/81, an audit of the RMC Corporation will be performed on the week of 9/14/81.
Included in the audit team will be & Health Physicist, a member of our l
QA D2pt., and one of our consultant physicians. The purpose of the audit is to assess the capabilities of R>C to handle a contaminated accident victim.
ITH4 5:
NRC Finding:
There.Ls no independent verification of the whole body counter perfomed sufficient to assure that the instrument is calibrated and functioning properly.
(Section 3.2)
RG&E Response:
There have been further refinements to the whole body counter source check procedure including acceptance criteria and directions for actions to be taken if discrepancies occur. These are currently in use and being incorporated in a formal procedure, to be implemented prior to September 10, 1981. The sources for the phantom were received in mid-August. We have contacted the vendor to help set up the phantom due to the complexity of the provided procedures. We are proceedirg as rapidly as possible and expect to conmence proforming independent Itantom calibmtions by October 30, 1981.
Although as stated in the 80-16 report a specific procedure for thyroid counting was not in place there are provisions in HP-2.2 for stationary counting. The purpose of stationary countirg is to count specific areas of the body. Steps are being added to the procedure to direct the operator how to perform thy-old, lurg ard gut counting.
ITEM 6:
NRC Finding:
Personnel are not provided sufficient opportunity to physically acquaint themselves with certain types of respiratory protective devices, particularly self-contained breathirg appamtus.
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)
RGsE Response:
In the August 18, 1981, response we indicated SCEA tmining would be gi'/en and documented for emergency rasponse personnel. This is now being done. SC-? (Fire Energency) tminirg has always included SCBA training and the sign-off sheet has been changed to reflect this for documentation purposes. Also, when the tmining section initiates SC-1 (Plant Radiation Emergency Plan) training, SCBA training will be included and documented for applicable personnel.
Also as part of an update to the Health Physics tminirg program more
" hands on" training will be included. This will be accomplished by setting up a sirrlated control point in a classroca in the new tmining area. This will be accomplished, hopefully, prior to the start of the next scheduled refueling outage.
In the interim more emphasis will be placed on hands on and demonstation in the current Health Prysics orientation progmm.
ITEA NRC Finding:
The calibration program and procedures for portable survey instrunents and installed area nonitors need to be revised to treet the reconmendations of ANSI N-323, " Radiation Protection Instrumentation Test and Calibration." Specifically, you need to develop operational source checks for portable survey instruments and portable area monitors as reconmended in ANSI N-323 (Section 3.3)
RG&E Response:
The following procedure is being developed to control source checks on portable plant equipment. 'Ihe procedure will be sutmitted to The Plant Operations Review Conraittee by 9/10/81.
To verify instrument operability all instruments which are available for routine use will be source checked daily. Each instrunent will be checked on a source by one of the HP/ Chemistry technicians as part of his daily routine. Acceptance criteria for each type of instrument will be developed for the sources utilized.
If instrunents do not meet the acceptance criteria they will be tagged out of service for repair or recalibration. Instruments not available for routine service will be segregated and source checked prior to use.
Also included in this program will be portable area nonitors and alarming dosimeters. Emergency Survey Center equipment will also be covered under a separate procedure.