IR 05000244/1982004
| ML20052B469 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/13/1982 |
| From: | Knapp P, Nimitz R, Rowe C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20052B463 | List: |
| References | |
| 50-244-82-04, NUDOCS 8204300461 | |
| Download: ML20052B469 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
-Report No. 50-244/82-04 Docket No. 50-244 License No. DPR-18 Priority
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Category C
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Licensee: Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14604 Facility Name: R. E. Ginna Nuclear Power Plant Inspection at: Ontario, New York Inspection conducted:
February 22-24, 1982 88 bu-("-/ f-J'2.
Inspectors:
~R.L.Nimitz,Rg6TitionSpecialist date m
$sk-k&L-f-/3-82.
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C. A. Rowe, Radiation Specialist date Approved by:
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Y"M~M P. J. Knapp, Chief, Facility Radiological date Protection Section
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Inspection Summary:
Inspectior on February 22-24, 1982 (Report No. 50-244/82-04)
Areas Inspected:
Routine, unannounced inspection of the licensee's implementation of corrective actions for Radiation Protection Program deficiencies identified during the NRC Health Physics Appraisal. The inspection involved 32 inspector-hours onsite by two NRC regional based inspectors.
Results:
No violations were identified.
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DETAILS
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Persons Contacted R. Biedenbach, Fire Protection and Safety Inspector
- J. Bodine, Quality Control Engineer R. Burt, Assistant Training Coordinator
- D. Filkens, Supervisor, Chemistry and Health Physics G. Lawless, Instructor-Training D. Morrill, Training Coordinator
- B. Snow, Plant Superintendent
- R. Zimmerman, NRC Senior Resident Inspector
- denotes those persons present at the exit interview on February 24, 1982.
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Inspection Purpose The purpose of this inspection was to review the licensee's implementation and adequacy of actions taken to correct radiation program deficiencies identified during the NRC's Health Physics Appraisal at the R. E. Ginna Nuclear Power Plant.
3.
Review of Licensee Corrective Actions for the NRC's Health Physics Appraisal Significant Appraisal Findings References:
NRC Health Physics Appraisal Report No. 50-244/80-16, dated June 15, i
1981.
Rochester Gas and Electric Corporation's initial. response, dated July 8, 1981 and supplemental response, dated August 20, 1981 to the Health
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Physics Appraisal (above).
l The significant appraisal findings, the licensee's response thereto and the review of the licensee's implementation and adequacy of corrective actions is presented in the following paragraphs.
Significant Finding 1
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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 responsibilities and authorities).
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Administrative 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)
(Item 50-244/80-16-01)
Licensee Response (July 8, 1981)
The licensee's response stated, in part, "The description of the Ginna Health Physics and Chemistry organization as depicted in Figure 2 of Inspection Report 80-16, was developed in a more formal manner at the close of the Health Physics Appraisal inspection in December, 1980...
Position descriptions are being formalized as part of a plant-wide program. A schedule for the completion of the Ginna Station Health Physics and Chemistry position descriptions and for related revisions to administrative procedures will be included in our forthcoming August 20, 1981 response. The position description for the Corporate Health Physicist was completed on November 21, 1980."
Licensee Response (August 20, 1981)
The licensee's response stated, in part, ".
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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
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Since the inspection,, unfortunately, one of the Health Physicists has left this Company for another job. Until he is replaced and the replacement is trained, Ine responsibilities of ALARA and respiratory protection coordination will have to be shared among the remainder of the staff... The position description for the Health Physics and Chemistry Organization should be completed by June 1, 1982
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Finding Review The inspector's review of the above indicated the licensee had revised the Health Physics and Chemistry Organization chart to reflect the current organization. This organization was noted to be consistent with that described in the Health Physics Appraisal Report.
The review indicated the position description for the Corporate Health Physicist was established on November 21, 1980.
The position description (termed position analysis by the licensee), was approved by the Manager - Nuclear Engineering, the Assistant Chief Engineer, and the Vice President - Engineering and Construction. The position analysis contains selection and qualification criteria and responsibilities. No authorities were specifie.
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The inspector noted that the position analysis indicates that the Corporate Health Physicist will support the licensee's facility as a shift Health Physicist during outages.
However, no minimum training was described in the analysis that this individual should receive prior to assuming that duty. This was discussed with the Corporate Health Physicist, who indicated that a review of the minimum training needed would be made.
Regarding the position descriptions for each position in the Health Physics and Chemistry Organization, inspector discussion with licensee representatives indicated the descriptions are being developed and were anticipated to be completed by June 1, 1982.
The inspector noted licensee representatives to indicate that the position descriptions would include selection and qualifi-cation criteria, authorities, responsibilities and hierarchy.
The inspector indicated the position descriptions would be reviewed during a subsequent inspection. (50-244/82-04-05)
Significant Finding 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.) (50-244/80-16-02)
Licensee Response (July 8,1981)
The licensee's response stated, in part, "Ginna Precedure HP-1.7, Film Badge Accuracy Check is now in formal use requiring the monthly irradiation of at least 12 vendor badges on a calibration source. Badge exposure levels, acceptance criteria and required documentation are specified in the procedure.
The results are reviewed by a Health Physicist to determine if any corrective actions are necessary.
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Licensee Response (August 20, 1981)
The licensee's response stated, in part, "Since the audit, we have instituted HP-1.7 " Film Badge Accuracy Test".
This procedure directs that a minimum 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 exposure level so if a discrepancy occurs, an evaluation can be performed using ANSI N-13.7.
As of August, 1981 a minimum 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 performed using ANSI N-1,
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Our current film badge supplier has submitted to and met all existing performance criteria...
In addition, film badge results are compared with results from two other dosimeters involving completely different methods of exposure determination.
Systematic errors in any of the dosimeters will be apparent when performing HP-1.4 (Dosimeter Discrepancy Evaluations)
Finding Review The inspector review of the above finding indicated the licensee established and implemented procedure HP-1.7, " Film Badge Accuracy Check, "on February 13, 1982. The procedure requires that 4 sets of 4 film badges receive exposures of 500, 1000, 1500 and 2000 millirem, respectively, for a total of 16 badges indicated (i.e., 4 badges receive 500 milliremen, 4 badges receive 1000 millirem, etc.).
The procedure also requires that 3 sets of 4 film badges receive beta absorbed doses of 150, 300 and 500 millirad for a total of 12 badges irradiated, (i.e., 4 badges receive 150 millirad, 4 badges receive 150 millirad, 4 badges receive 300 millirad, etc.).
After irradia-tion, the badges are sent to the licensee's vendor for processing.
Evalua-tions are required to be performed if the reported results are not within 1 25's for gamma and 1 50's for beta of the doses delivered. These evaluation criteria were noted to be consistent with those presented in ANSI-N13.11,
" Draft American National Standard Criteria for Testing Personnel Oosimeter Perfctmance".
Regarding Procedure HP-1.4, " Dosimetry Discrepancy Evaluations," the inspector noted this procedure number was a misnomer, the procedure addressing these evaluations was HP-1.5.
The inspector's review of Procedure HP-1.5, dated August 31, 1978, indicated all personnel whose self-reading pocket dosimeter total for a badge period exceeds the film badge reported results by 300 millirem are to be listed on a Dosimeter Discrepancy Evaluation Form.
The licensee then reads out the individuals TLD and compares the TLD results to the film badge results.
Based on the comparison of the results with respect to the limits presented in procedure H.P.-l.5, an evaluation is performed.
The review indicated that Procedure H.P.-l.5 provides no guidance if the total self-reading dosimeter total for the badge period is less than it's film badge result.
In addition, the procedure provides limited guidance for actions to be taken in the event a significant dose discrepancy is
identified, e.g., minimum required evaluation, prohibition of further exposure to the individual pending resolution, and notification of the NRC in accordance with 10 CFR 50.72.
The incpector's discussions with the licensee's Supervisor, Chemistry and Sealth Physics, indicated procedures would be reviewed and revised as necessary within 30 days to ensure the above matters were addressed.
(50-244/82-04-01).
Regarding the tests of the film badges, the inspector noted that the maximum gamma exposure delivered to the film badge was 20's of the maximum value recommended for the protection test range in ANSI-N13.11 while the i
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beta dose delivered was 5*4 of the recommended maximum value provided in ANSI-N13.11 and Regulatory Guide 8.3, Film Badge Performance Criteria.
In addition, the licensee does not irradiate selected badges with mixed beta /
gamma radiation as recommended by ANSI-N13.11.
The inspectors' discussions with the licensee's S.upervisor. Chemistry and Health Physics regarding testing indicated that the licensee's vendor had met the dosimetry testing criteria described in NUREG/CR-1063, Performance Testing of Personnel Dosimetry Services:
Procedures Manual, and that their testing, as described in Procedure HP-1.7, served only as a check of their vendor.
The inspector acknowleged the above and noted that the licensee is currently in the process of establishing an in-house dosimetry system which will meet the recommendation of ANSI-N13.11.
This system is anticipated to be in place by approximately May, 1982.
The inspector indicated that the new program will be reviewed during a subsequent inspection.
(50-24A/82-04-06)
Significant Finding 3 There are no adequate procedures formally established, maintained and implemented that permit the evaluation of uptakes of radioactivity from air samples or bioassay results.
(Section 3.2) (50-244/80-16-03)
Licensee Response (July 8, 1981)
"The dose calculational techniques currently in use at Ginna Station represent standard methodology for evaluating biological uptakes of radioactivity (e.g. ICRP-2). However, we will incorporate appropriate instructions based upon such methodology into formalized procedures for the evaluation of air sample and bioassay data. These procedure revisions will be completed by September 10, 1981."
Finding Review The inspector review of the above finding indicated that the licensee established and implemented Procedure HP-2.5.2, " Determination MPC-Hours From Body Burden Analysis, "on October 29, 1981 to provide a method of calculating MPC-hours in cases of acute exposure to radioactive material when the body burden is known from bioassay results.
In addition, the licensee established and irplemented Procedure HP-2.5.3, " Calculation Methods For Internal Dose and Body Burdens, "on December 14, 1981.
This procedure provides methods of calculating the radiation dose to internal organs resulting from intake of radioactive material.
The inspector review of Procedure HP-2.5.2 indicated that it incorporates the ICRP-2 model and associated deposition factors. The inspector noted
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that the requirement to perform an evaluation and take actions to prevent recurrence was included in the precautions and limit values section of the procedure. -The inspector review of the procedure indicated it incorporated the appropriate calculational methods for determining internal dose.
The review of procedure H.P.-2.5.2 indicated that all inhaled material was assumed to be insoluble, with the lung as the critical organ, with the exception of iodine and cesium, which were assumed to be soluble, with their critical organs being the thyroid and whole body, respectively.
The inspector review of the use of cesium as a soluble radionuclide as compared to 10 CFR 20, Appendix B, Concentrations in Air and Water Above Natural Background, indicated that the soluble concentration value was 6 times the insoluble concentration value. Consequently, the inspector noted that personnel exposure calculations using the soluble value may underestimate exposure by the same factor.
Licensee representatives acknowledged the above and indicated that the procedure would be revised within 30 days to include precaution statements directing the reviewer to check for insoluble cesium and use the appropriate value provided in Appendix B to 10 CFR 20.
The inspector indicated the above matter would be reviewed during a subsequent inspection.
(50-244/82-04-02)
Significant Finding 4 There are no 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) (50-244/80-16-04)
I Licensee Response (July 8, 1981)
"Ginna Station Procedure HP-2.5, "Whole Body Count Evaluation." currently provides general instructions for initiating the collection and analysis of biological samples.
An offsite contractor is utilized for emergency medical support and bioassay evaluation.
The contractor has supplied Ginna Station with kits for the collection of biological samples, which can then be counted at Ginna or by the contractor. We are planning a QA audit of the contractor offsite facilities before September 10, 1981. A Health Physicist will accompany the audit team to assist in the review of procedures and calibration data. We are currently reviewing our own bioassay program and procedures and will providt additional comments in the forthcoming August 20, 1981 response.
Licensee Response (August 20, 1981)
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The licensee's response stated, in part, "
.. Formal procedures are being written for the collection, handling, and transportation of urine and feces
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samples.
The procedures are being written to incorporate the recommendations of ANSI N-343 as appropriate.
Analysis of the urine and feces samples can be performed using our standard counting procedures adjusting sample size and geometry for different sample activities. Although we do not normally perform 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...
An audit of our contractor will be performed on the week of September 14, 1981.
Included in the audit team will be a Health Physicist, a member of our QA Dept., and one of our consultant physicians. The purpose of the audit is to assess the capabilities of RMC to handle a contaminated accident victim."
Finding Review The inspector review of the above finding indicated that the licensee had established and implemented Procedure HP-2.5.1, " Bioassay Samples Collection, Handling and Analysis," on October 7, 1981, to provide for proper collection, handling, and analysis of urine and fecci samples to insure accurate estimates of radioactivity in the body.
The review of the procedure indicated that samples are collected using a prepackaged sample collection kit. The procedure provides precautions and limits for the prevention of contamination of samples, provides sample volumes, and other information important to the analysis.
It was noted that Procedure HP-2.5.1 did not indicate what use would be made of the data obtained from analysis of bioassay samples. This matter was discussed with the licensee representatives who indicated the procedure would be revised within 30 days to specify that data from evaluation of bioassay samples be utilized in the determination of intake estimates. The inspector indicated this would be reviewed during a subsequent inspection.
(50-244/82-04-03).
The inspector review of Procedure HP-2.5 Revision 2, "Whole Body Count Evaluation," indicated it requires bicassay samples to be taken and the person recounted if a single isotope or the sum of all isotopes exceeds 10%
of the maximum permissible organ burden.
The inspector also noted that in the event of the identification of an exposure in excess of 40 MPC-hours in 7 consecutive days, actions are to be taken to prevent recurrence.
Records of evaluations and actions taken are also to be maintained.
The licensee performed an audit of their offsite contractor, used for emergency medical support and bioassay evaluation, on September 18, 1981.
The audit team included a Health Physicist, QA department member, and a consultant physician.
Significant Finding 5 There is no independent verification of the whole body counter performed, sufficient to assure that the instrument is calibrated and functioning properly.
(50-244/80-16-05)
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Licensee Response (July 8, 1981)
"The offsite contractor used for the whole body counter,operatiori performed a calibration of the unit using NBS traceable sources and a phantom in November, 1980. Currently, Ginna Station performs source checks on the whole body counter each day the unit is operated, as specified by Procedure HP-2.2, 'Whole Body Counter Operation.'
A phantom has been purchased for in-house use, and we are currently awaiting delivery of a set of calibration sources to use with the phantom.
It is anticipated that we will have complete in-house capability and procedures to perform independent phantom calibrations cf the whole body counter by September 10, 1981."
Licensee Response (August 20, 1981)
"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 incor-porated 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 proceeding as rapidly as possible and expect to commence performing independent phantom calibrations 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 counting is to count specific areas of the body.
Steps are being added to the procedure to direct the operator how to perform thyroid, lung and gut counting. "
Finding Review The inspector review of the above finding indicated that the licensee
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established and implemented Procedure HP-2.2.2 "Whole Body Counter Calibration Verification," on January 15, 1982.
The review of Procedure HP-2.2.2 indicated that the procedure required a
" standard man" masonite phantom be used for the whole body counter calibration verification. The calibration verification is performed using NBS traceable sources once quarterly and after any maior maintenance of the counter. The procedure provides for separate thyroid, lung, and gut count, and contains both precision and accuracy estimates for the verification.
The review also indicated that the licensee established and implemented Procedure HP-2.2.1, "Wnole Body Counter Source Check," on November 20, 1981. The procedure requires a daily source check of the whole body counter using Co-60.
The response of the counter must be within + 5't,of the previous check source reading after correction for decay. A control chart is used to track the daily performance of the whole body counte.
The inspector review of Procedure HP-2.2, Revision 11, "Whole Body Counter-Operation," indicated the Procedure required a source check be performed, as described in Procedure HP-2.2.1, each day the counter is used.
The review of procedure HP-2.2.2 indicated 50 Co-60 sources, 50 Cs-137 sources, and 50 simulated I-131 sources (Ba-133 and Cs-137) were available for calibration verification. These sources were placed inside the masonite phantom for counting.
The inspector noted that ANSI-N343, American National Standard for Internal Dosimetry for Mixed Fission and Activation Products, recommends in Section 15.2 that measurements of a calibration phantom be made for a phantom that contains a range of radioactivity.
The inspector noted that although the licensee has a range of activity available for checking its calibration of the whole body counter, the licensee's procedures do not specify the number (i.e. range) of sources to be used in the calibration.
In addition, although source checks were performed daily, the procedures did not provide for review and/or changing of the daily source check mean value based on a before and after calibration count of the source used for the daily counts.
The above matters were discussed with cognizant licensee representatives who indicated that procedures would be revised within 30 days to specify the number of sources to be used for the whole body counter calibration verification and to provide for comparision and changing of daily source check value based on a before and after calibration count of the source check.
The inspector indicated the above matters would be reviewed during a subsequent inspection (50-244/82-04-04).
Significant Finding 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)
(50-244/80-16-06)
Licensee Response (July 8, 1981)
The licensee's response stated, in part, "... To provide additional hands-on experience in the general respiratory training program, masks will be made availabic for donning during the class. The instructor will review the proper mask donning procedure and the Mask Use Check Sheet, used in conjunction with Procedure HP-12.6, prior to performing the quantitative fit test. This training approach will become effective as of July 13, 1981
. SCBA equipment use and actual donning will be performed and documented
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separately as part of Ginna Station's emergency response training. We will provide an expected implementation date in our forthcoming August 20, 1981 response."
' Licensee Response (August 20, 1981)
The licensee's response stated, in part, "In the August 18, 1981, response we indicated SCBA training would be given and documented for emergency response personnel. This is now being done.
SC-3 (Fire Emergency) training has always included SCBA training and the sign-off sheet has been changed to reflect this for documentation purposes. Also, when the training 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 training program more ' hands-on' training will be included. This will be accomplished by setting up a simulated control point in a classroom in the new training area.
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Finding Review The inspector review of the above finding indicated the licensee established and implemented Procedure HP-12.6, Revision 13, " Issuance, Proper Use and Return of Respirators," on October 29, 1981 to ensure that respiratory equipment is properly used to obtain the required protection factor and is returned for cleaning and inspection.
The procedure requires satisfactory completion of respirator training before personnel are issued a respirator.
Inspector review of the lesson outlines, used in the respirator training program, indicated the current program provides an opportunity for hands-on training.
The lesson outline does not require individuals to don respirators.
Licensee training personnel stated that different types of respirators were available in the classroom and students do use the equipment including donning of the self contained breathing apparatus.
The inspector reviewed Procedure HP-12.2, Revision 7, " Medical Check, P' ting and Trairing of Personnel Using Respirators," established and 15.. Amented on April 4, 1980. The inspector review of the procedure indicated it describes the Respiratory Protection Training Program and requires that a negative pressure test, a quantitative fit test and medical questionnaire be completed prior to use of respirators.
The inspector noted that although a review was being performed by a Training Instructor to ensure personnel w re cognizant in the use of respiratory protective equipment, no uniform acceptance criteria was established for use in evaluating an individual's retention of training material or his ability to don, test and remove respiratory protective equipment.
The above matters were discussed with members of the licensee's training organization who indicated minimum performance criteria would be developed and used for evaluating an individual's ability to properly don, test and remove respiratory protection equipment including criteria for proper use
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of self contained breathing apparatus. This was anticipated to be completed within several days.
The inspector indicated the above matter would be reviewed during a subsequent inspection. (50-244/82-04-07)
Finding 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) (50-244/80-16-07)
Licensee Response (July 8,1981)
"We are in the process of establishing acceptance criteria for our portable survey equipment and will implement a source check program for instruments in use by September 10, 1981. "
Licensee Response (August 20, 1981)
"The following procedure is being developed to control source checks on portable plant equipment. The procedure will be submitted to The Plant Operations Review Committee by September 10, 1981.
To verify instrument operability all instruments which are available for routine use will be source checked daily.
Each instrument 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 used.
If instruments do not meet the acceptance criteria they w. 1 be tagged out I
of service for repair or recalibration.
Instruments not available for routine service will be segregated and scurce checked prior to use. Also included in this program will be portable area monitors and alarming dosi-meters.
Emergency Survey Center equipment will also be covered under a separate procedure."
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Finding Review The inspectur review of the above finding indicated that the licensee
established and implemented Procedure HP-7.31, " Daily Instrument Source
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Checks, "on October 7,1981 to provide a method for performing and documenting -
daily source checks for portable survey instruments and portable area monitors.
Inspector review of the procedure indicated that an acceptance value within + 20% of the expected value is required.
Instruments not meeting the acceptance criteria are taken out of service and tagged.
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'T The review of the licensee's actions indicated that the daily source check is not consistent with Section 4.6 of ANSI-N323, 1978 which requires that the instrument be tested with a check source during operation and prior to each intermittent use.
In addition, it was noted that source checks of the Emergency Survey Center equipment were not addressed in Procedure H.P.-7.31 nor were they covered in a separate procedure.
Regarding the lack of a procedure for checking the Emergency Survey Center equipment, licensee representatives indicated the source checks were being performed, however the requirement remained to be included in a procedure.
Licensee representatives indicated appropriate procedures would be revised within 60 days to address this matter.
Regarding the source checking of instruments, licensee representatives indicated the source used to perform source checks was stored in a laboratory near the Health Physics main control point and was available for use in checking a particular survey instrument prior to each intermittent use.
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addition, licensee representatives indicated the daily source check was perferred because of the assurances that the instrument was checked and documented as being checked at least once a day.
The inspector indicated that the procedure revision for source checking Emergency Survey Center equip) ment would be reviewed during a subsequent inspection. (50-244/82-04-08 4.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on February 24, 1982. The inspectors summarized the purpose, scope and findings of the inspection.
Licensee representatives indicated the following actions would be taken within 30 days:
l Procedures for dose discrepancy evaluation would be revised to provide
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appropriate guidance for actions to be taken when a significant dose discrepancy is identified.
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A precautionary statement would be included in appropriate procedures for intake analysis to ensure appropriate cesium concentration values are used.
Whole body counter operation procedures would be revised to specify
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range of sources in calibration and to relate daily counter source check to latest calibration.
Procedures for analysis of bioassay samples would be revised to include
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guidance for use of bioassay sample data.
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l-A worker performance evaluation sheet for respiratory protective
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equipment. training would be established.
In addition, licensee representatives indicated appropriate emergency procedures would be revised within 60 days to provide guidance for source checking emergency instruments.
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