IR 05000244/1987019

Insp Rept 50-244/87-19 on 870727-31.Violation Noted.Major Areas Inspected:Occupational Radiation Protection Program, Including Status of Previously Identified Items,Organization & Mgt Controls,Audits & External Exposure Control

ML20238D050
Person / Time
Site:	Ginna
Issue date:	08/28/1987
From:	Lequia D, Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17261A598	List: IR 05000244/1987019
References
50-244-87-19, NUDOCS 8709100536
Download: ML20238D050 (11)

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> :l U.S. NUCLEAR REGULAT0hY COMMISSION

REGION I

s Report N /87-19 ,

Occket N :

License N DPR-18 Category C

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licensee: Rochester Gas and Electric Corporation 49 East Avenue 1 Rochester, New York 14649 Facility Name: Ginna Nuclear power Plant Inspec' n At: Ontario, New York Inspection Conducted: July 27-31, 1987 g- %  ;

M Inspector {J.//dth~ M

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McFadden,(_S(, Radiation Specialist Bbe/3 7 ,

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fx?g3 / Info date D. LeQuia,'J6diat4on Specialist

Approved by: R L N cd6 fn glnhG M. Shanbaky, Chief, Facilities Radiation date protection Sectiin

,im pection Summary: Inspection on July 27-31, 1987 (Inspection Report No. 50-244/87-19) ,~

Areas Inspected: Routine unannounced inspection of the occupational radiation protection program including: status of previously identified items,

organization and management controls, audits, external exposure control, internal exposure control, control of radioactive material and contamination, surveys and monitoring, and ALARA. Two regionally-based inspectors were on-site for the inspectio Results: One apparent violation was identified. Failure to maintain an acceptable written procedure for a calibration required by a technical specification surveillance requirement (Section 8.0). Two unresolved items were identified (Sections 5 and 6). l One inspector follow-up item was identified (Section 8.0). The licensee was found  !

to be making improvements to their radioactive contamination control progra PDR ADOCR 05000244 G PDR

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DETAILS (i[

1.0 Persons Contacted During the course of this inspection, the following personnel were l contacted or interviewe ,,

1.1 Licensee Personnel D. Bryant, QA Engineer / Operations ^[

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• Filkins, Manager - Health Physics and Chemistry [

• W. Goodman, HP Foreman

J. Jones, I&C Foreman -

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• R. Kober, VP Electric Production .

• T. Meyer, Superintendent - Ginna Support Services

• F. Mis, Health Physicist # l

• R. Popp. !&C Technical Assistant

• Quinn, Corporate Health Physicist 7

• Snow, Superintendent Nuclear Production P l

• Spacher, Health Physicist I

• Spector, Superintendent - Ginna Production

• J. Supina, Dosimetry Supervisor /ALARA Coordinator

• S. Warren, Health Physicist i

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i 1.2 NRC Personnel Attending the Exit Interview T. Polich, Senior Resident Inspector

" Attended the Exit Meeting on July 31, 198 J Additional licensee personnel were contacted or interviewed during

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this inspectio ,

2.0 Purpose

The purpose of this inspection was to review the licensee's occupational h

j radiation protection program with respect to the following elements:

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Status of previously identified items

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Organization and management controls i

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External occupational exposure control and personal dosimetry

• Internal exposure control and assessment

Control of radioactive materials and contamination, surveys and monitoring a

Maintaining occupational exposures ALARA

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3.1 (Closed); Follow-up Item (82-09-01); 16 l

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.L Verify that radiological warning signs are covered in the

" Administrative / Security Indoctrination"' course. Inspector. review @% q l

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of Lesson Plan No..GGE01C, Rev. 2, entitled: " Administrative / @ l Security /QA Indoctrination," verified that employee training relative  % l to radiological warning signs has been included in the lesson plan on Q J page 4 of 31. Based upon this review, this item is close A

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3.24 (Closed); Follow-up Item (82-09-02):

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-Licensee to proceduralize guidance for " Visiter Dosimeter Log," i defining who is classified as a. visitor, outlining visitor escort %yj '

responsibilities, and describing how the log is administere .

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,y Inspector review of Procedure No. HP-4.1.1, " Untrained Visitor Entry y to Controlled Areas," Rev. 6, determined that the licensee has W proceduralized the guidance necessary for. administration of the %A

" Visitor Dosimeter Log". Inspector review of. Visitor Dosimeter Log '"

entries for July 15 and 16,1987, verified that the-log is-being maintained in accordance with procedural guidanc Based on thi review, this item is close !

3.3 (Closed); Noncompliance (Severity Level 5) (82-09-03): /

M Special work permits (SWPs) incorrectly specified work locations, radiation dose rates, and radioactive contamination levels. During

N NRC Inspection No. 87-05, selected SWPs being implemented during the i-outage were reviewed, and incorrect specifications were not f identified. Based on this finding, this' item is considered close l, &

i l 3.4 (Closed); Followup Item (82-11-01): "

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A Evaluation of interlaboratory comparison program results. Followup 7 item, 85-18-02, also addresses this subject and therefore, this item (82-11-01) is considered closed administrativel .5 (Closed)1 oll_owup_I F tem _(82-11-02):

Evaluation of TLD measurements progra Follow-up item, 84-20-02, also addresses this subject and, therefore, this item (82-11-02) is considered closed administrativel !

4.0 Staffing, Management and Organization '

The licensee's organization, staffing and motivation to effectively centrol radiation and radioactive materials was evalo 'ad against the <

following criteria:

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Technical Specifications. Section 6, " Administrative Controls";

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Regulatory Guide 1.8, " Personnel Selection and Training"; *[

NUREG/CR-1280, " Power Plant Staffing";

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ANSI-N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel." ..y Licensee performance relative to these criteria was determined by: @

Review of organizational charts; q

Discussions with cognizant personnel; I

Review of procedures; and 1

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Review of the Incident Logboo '

Within the scope of this inspection, no violations were note The licensee appeared to have a motivated staff that was organized as '

identified in the facility Technical Specifications (TS). Within this structure, Radiation Protection Technicians provide both radiation 3 protection and chemistry support. During non-outage conditions, the 1 majority of the technicians work on day-shift, with a single technician e assigned to each backshift. However, during outages, two twelve-hour ,

shifts are established to provide around the clock coverage. To y strengthen management controls during these outages, two senior ,

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technicians are advanced to Assistant Radiation Protection Foreme ,

Contractor personnel are routinely used to augment the station HP staff

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during outages. In addition, some contractor '.resence is maintained +

on-site between outages. At the time of this inspection, two contract HP s ,

technicians were providing coverage for on going work, while two other contract personnel were operating the protective clothing laundry facility.

l One weakness relative to organizational charts was observed by the l inspecto Specifically, some organizational charts, titles and responsibilities relative to the Health Physics Section, as identified in procedure A-201 "Ginna Station Administrative and Engineering Staff Responsibilities," Rev. 20, did not match those in the Technical Specifications. The inspector discussed this issue with the Health Physics and Chemistry Manager who stated that he was currently in the process of making the necessary procedure revisions to ensure proper correlation of these two documents. This is expected to be in place by October 30, 1987..

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hy inspector review of the Incident Logbook, a corrective action system b c>tablished by HP management to identify and correct radiological D deficiencies, found it to have significant' weaknesses. Specifically, a implementation of the log book was not procedurally addressed, nor was  ;

any guidance on what was to be recorded in the log book readily -'

availabl Furthermore, trending and tracking of the recorded' data was not being /'

done in a systematic manner, This system, as currently used, would not llc satisfy the five criteria for licensee self-identification as encouraged by the NRC in 10 CFR 2, Appendix When this item was discussed with -

the licensee, they stated that.a procedure was currently under s development to implement a corrective action system that would address the licensee self-identification criteria as referenced above. The licensee stated that this item would be completed by January 30, 198 .

5.0 Audits . :

The licensee's program for audits of the Radiological Control Program was reviewed against criteria contained in: ,

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Technical Specification 6.5 " Review and Audit";

Regulatory Guide 1.146 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants";

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Rochester Gas and Electric Corporation Ginna Station " Quality Assurance Manual." ~ /^

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These li:ensee's performance in this area was determined by the following:

Discussions with cognizant personnel;  %

Review of auditer qualification / certification records; '

Review of the following audits:

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86-36: CK " Audit of Ginna Station Health Physics."

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86-59: OB " Audit of Ginna Station He'Ith Physics, Chemistry, and Environmental Controls"

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87-03: JB "Ginna Station Health Physics Audit Report"

Review of Audit Checklists; and l

• Review of Audit Findings / Corrective Action l l

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, 1 Inspector review of Health Physics audits found them to be programmatic gl in nature with sufficient detail for ef fective assessment of the Health Physics Progra These audits were led by qualified Lead Auditors, with ' 4* -

additional health physics qualified technical specialists on the audit , ,

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Within the scope of this review one weakness was identifie Specifically, Technical Specification 6.5.2.8b requires that an audit of i

"the performance, training and qualifications of the operating and technical staff [be performed] at least once a year." Inspector review of the above referenced audits identified that a sampling of the performance, training and qualifications for health physics professional -

technical personnel, to meet ANSI N18.1-1971 requirements, was not included within the scope of these audits. After identifying this weakness to the licensee, they researched previous audits back to 1984, and determined that only the qualifications of HP technicians and the HP .

Foreman had been audited. However, some individuals who routinely audit l l this area were unavailable for questioning during the week of this I l inspectio The licensee stated that these records may be available,.but )

I could not be located until the personnel returned. Therefore, this item j will remain unresolved, pending the licensee's investigation into j previous audits and audit checklists for the necessary documentation l (87-19-01).

6.0 External Occupational Exposure Control and Personnel Dosimetry The licensee's program for external occupational exposure control and personnel dosimetry was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation

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Applicable Technical Specifications The licensee's performance relative to these criteria was determined by:

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Discussions with licensee personnel

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Independent radiation dose rate measurements

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Observations by the inspectcr during a tour of the controlled area

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Review of documentation and records During this review, the individual cumulative dose records for 1987 (whole body, skin, and extremities - based on TL0s and SRDs) were reviewed. Based on this review, it appeared that the licensee had adequately implemented ex*.ernal exposure controls during the 1987 outag _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _

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During review of NRC Form 5's, the inspector noted a recordkeeping problem. 10 CFR 20.401(a) requires that extremity dose include the dose

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mg/cm2 or less. Several NRC Form 5's for extremity dose were reviewe The inspector noted that one of these had a penetrating / deep. dose recorded rather than a nonpenetrating / shallow dose. When such an NRC Form 5 for extremity dose is initiated, the licensee maintains it for calendar quarters and enters whole body TLD badge results. The licensee stated that it was standard practice to add the penetrating / deep dose recorded on the ';; . ,

whole body TLD badge to this extremity record. The correct dose from a I whole body TLD badge to be added to an extremity dose record is the nonpenetrating / shallow dos <

The inspector also noted that since the shallow dose is usually equal to or greater than the deep dose, the correction of the extremity dose records will result in some recorded extremity doses being increase This could theoretically cause an increased extremity dose record to exceed the quarterly exposure limits. The licensee stated that the corrections would be made. This matter will remain unresolved and wili be further reviewed in a subsequent inspection (87-19-02). Inte_rnal Exposure Control and Assessment  !

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The licensee's program for internal occupational exposure control and assessment was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation

Applicable Technical Specifications The licensee's performance relative to these criteria was determined by:

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Discussions with licensee personnel

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Review of daily MPC-hours tracking records and of selected whole body counting results Review of the daily MPC-hours tracking records and of the whole body coun *g results indicated that the licensee had implemented adequate interiil exposure control measures during the 1987 outag Within the scope of this review, no violations were identified.

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b During review of NRC Form 5's, the inspector noted a recordkeeping problem. 10 CFR 20.401(a) requires that extremity dose include the dose 4 delivered through a tissue equivalent absorber having a thickness of 7-mg/cm? or less. Several NRC Form 5's for extremity dose were reviewe The inspector noted that one of these had a penetrating / deep dose ,

recorded rather than a nonpenetrating / shallow dose. When such an NRQ Form 5 for extremity dose is initiated, the licensee maintains it for calendar quarters and enters whole body TLD badge results. The licensee' stat 4d that it was standard practice to add the penetrating / deep dose recorded op the whole body TLD badge to this extremity record. The correct dose frodLa whole body TLD badge to be added to an extremity dose record is the '

nonpenetrating / shallow dos The inspector also noted that since the shallow dose is usually eqJal to

' or greater than the deep dose, the correction of the extremity dose records will result in some recorded extremity doses being increase This could theoretically ceuse an increased extremity dose record to exceed the quarterly exposure limits. The licensee stated that,the corrections would be made. This matter will remain unresolved and will be further reviewed in a subsequent inspection (87-19-02). Irfternal Exposure Control and Assessment '

The licersee's program for internal occupational exposure control and assessment was reviewed against criteria contained in:

10 CFR 20, Standards for Protection Against Radiation

Applicable Technical Specifications The licensee's performance relative to these criteria was determined by:

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Discussions with licenste personnel

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Review of daily MPC-hours tracking records and of selected whole body counting results s Review of the daily MPC-hours tracking records and o$ fna whole body counting results indicated that the licensee had implem:nted adequate inte/nal exposure control measures during the 1987 outag Within the scope of this review, no violations were identifie /

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8.0 Control of Radioactive Materials and Contamination, Surveys, and Monitoring The licen3ee's program for control of radioactive materials and ,

contamination, surveys, and monitoring was reviewed against criteria l contained in:

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10 CFR 20, Standards for Protection Against Radiation i

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Applicable Technical Specifications The licensee's performance relative to these criteria was determined by:

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Discussions with licensee personnel

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Observations by the inspector

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Review of survey results, instrument calibrations, and procedures During this review, the inspector noted that several improvements had been made by the licensee in regard to previously identified deficiencie The licensee was observed implementing measures to change the practice of'

l reusing potentially contaminated rubber overshoes during this inspectio Procedures had been developed, established and implemented for the cali-bration of the Smart Radiation Monitor (SRM-100) and for the control of radiation instrumentation undergoing evaluation. The inspector noted that the wall flow chart for personnel contamination incidents now reflects the guidance in the approved procedure addressing the same subject. The personnel contamination incident log was revised to allow the surveyor to enter his initial During review of the calibration records for the technical specification -

radiation monitors, the inspector noted that Procedure No. CP-224 (Re No. 6), Calibration and/or Maintenance of Containment High Range Area 1 Monitors, was unacceptable since it did not provide for channel j calibration with a radiation source for at least one decade below 10 1 R/ hour. A licensee representative stated that the requirement for J channel calibration with a radiation source had been inadvertently left out between revisions 3 and 4 of this procedure. The licensee representative stated that a radiation source was still used for the -

channel calibration even though the procedure did not require i liowever, records of the results of the channel calibrations with a radia-tion source for the last several refuelings were not available. Technical Specification 6.8.l(a) requires that there be procedures for calibration requirements in the technical specifications. The licensee's technical .;

specifications require that the containment area high range monitors be  !

calibrated each refueling and that this calibration utilize a radiation i source. The calibration procedure does not address thi This is an apparent violation (87-19-03).

During review of calibration records for area radiation monitors R1 i

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,7 thepugh P.3, the inspedtor notid that ifor at least R1, R3, R4, an { a i /RtJ some pctual readings were sot in igreement with the expecteo value' ;

J jf ai.bi monitor hai three readou'.,s (drawer, recorder, and ccmputer). The actt..il add' expected readings at the drawer readout were in ancemen l

,i But the recorder and computer readouts were over-responding by a factor 'gl )

of 2 to 4.5. The licensee stated that ; rouble cards had beer,' issued and . 'J !

that thiv situation was being evaluated by the licensee and by the I l

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.Aonitorirg system supplier. Triis item will be nyiewed in a future InspectYn(87-19-04).

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9.0 A_LAtlA ft

', .,l c Nelicense'sALAPgpro;ramwasevaluatedagainstcrikeriacontainedin  ! ,

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) j rs t - 10 CFR 20.1 " Purpose"; ;f

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Regulatory Guide 6'.8, "Information Relevant To Ensuring The ,.-

Occupational Radiation Exposures At Nuclear Power Stations Will Be ' d l As low As Is Ren onably Achievable" (ALARA)- ]'L ;

Regulatory Guide 8.10, " Operating Philosophy For Maintaining n L ;\j Occspitjonal Radiation Exposures As low As Is Reasonably Achievable;

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Regulati y Guide 8.19, 'Occupaticul Radiation Dose Assessment In e' L f Light-MkerReactorPowerPlantsDesignStageMan-RemEstimate3" f

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Discui,sions wich cognizant per eb

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Tours of' radiologically controlled areas; '

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Review of the following licensee procedures;  !? I i

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A-1.5 " Keeping Occupational Exposure at Ginna ALARA " Rev. ' ,' ,

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A-1.6.1 "Docanentation of ' As Low As Reasonably Achievable'

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Revici of RG&E *hrformance Indicator Goals Table";

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Review of Rgoiation Work Permits; ,

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Inspection of ALARA (leviews; and

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Review of Corpo a fand Plant ALARA Committrh .% ding Minutes >

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With*n the scope of this review, no violations were observed. The , )

licensee has implemented an ALARA Program with a well-ordered system for maintenance of ALARA records. The program is administered by an ALARA

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Coordinator and a Health Physicist. Corporate and Plant ALARA committees have been established to integrate the ALARA concept throughout the RG&E Corporatio i i For 1986, a refueling year, a station goal of 375 person-rem had been i established. The station expended a total' of 363 person-rem that yea I J' For 1987, also a refueling year, a goal of 375 person-rem was again g!

selected based upon the anticipated workscope. This level of person-rem  ;

expenditure is about average for a pressurized water reactor. At the time j of the inspection, an exposure of 304 person-rem had been received thus I far into the year. Based upon the current average of 5 person rem per i month for non-outage conditions, it appears that the 1987 station exposure will be at, or slightly under, the established goa J Within the scope of this inspection the following weaknesses were identified:

J Procedure A-1.5 " Keeping Occupational Exposure at Ginna ALARA", Re , step 1.5, states that the Corporate ALARA Committee"... shall i meet at least semi-annually. " However, in 1986, the Corporate

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ALARA Committee did not hold a semi-annual meeting for the second-half of the year. This indicates a lack of management I attention to detail, and failure to follow a procedural requiremen . There is no effective mechanism in place to ensure that ALARA requirements, specified by the ALARA committee, are incorporated into the RWP or passed on to the worker. The current practice is to i document spe:!fic ALARA actions for a given task into the ALARA )

Committee Meeting Minates. These minutes are then sent to each person that attended the meeting. The Radiation Protection Foreman,  ;

who attends these meetings, is supposed to pass on these ALARA 1 requirements via " word of mouth" to the personnel who write the RWP This appeared, to the inspector, to be a very cumbersome method of data transmission with many potential pittalls. The inspector discussed this item with the licensee who stated that they were developing a method to improve communication of ALARA requirements. The licensee stated that this would be in use before

), the next outage.

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10.0 (Jnresol_ve_d Item Unrpsolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-  !

ance, or deviation Unresolved items disclosed during this inspection are discussed in sections 5 and 6.

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11.0 Exit Interview '

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The inspector met with the personnel denoted in section 1.0 at the j conclusion of the inspection on July 31, 1987. The scope and findings of I the inspection were discussed at that tim l

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