IR 05000245/1985023

Insp Repts 50-245/85-23,50-336/85-28 & 50-423/85-47 on 850805-09.No Violations Identified.Major Areas Inspected: Personnel Selection,Facilities & Equipment,Dose Assessment, Qa,Documentation & Recordkeeping & Organization

ML20133B364
Person / Time
Site:	Millstone
Issue date:	09/11/1985
From:	Cioffi J, Jang J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133B359	List: IR 05000245/1985023 ML20133B356
References
50-245-85-23, 50-336-85-28, 50-423-85-47, NUDOCS 8510030235
Download: ML20133B364 (10)

Text

{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-245/85-23 50-336/85-28 Report N /85-47 50-245 50-336 Docket N OPR-21 - C CPR-65 - C License N CPPR-113 Priority - Category B Licensee: Northeast Nuclear Energy _ Company P.O. Box 270 Aartfo dl ~ C6nnect_icut 061_41-0270 Facility NaTe: Millstone l u 2t_3 Inscection At: Waterford _CT 1 and Berlin,_CT Inspection Conducted: August 5-9, 1985 I n w. c t'> rs :

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A. C.foffi, Radt L on Specialist, PWR ll _ W date ad Safety Section h - Ja, n[Jang, Radiatierr eosimet Y specialist Y [[ date-- J Approved by: ,gt;fub j{Arw/ [_ M. Shanbaby, Chief, PWR Aadiation _2[//.date

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Safety Section Inspection su-~.ary: Inspection on August 5-9, 1985 (Combined Rep ~ ort N ;$0-336/81-128;;_60-423/85-47)_., An'a s, I n spec t ed :

,  Special, unannounced inspection of the licensee's dosimetry progra Areas reviewed included: status of previously identified items, orpnization, personnel selection, facilities and equipment, calibrations, dose assesvent, quality assurance, documentation and recordkeeping, comparison of the licensee's environmental TL0s with NRC, and an independent performance tes Results: Within the areas inspected, no violations were identifie PDH ADUCK 05000245 0  Pult

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. DETAILS ! 1.0 Personnel Contacted . . *J. Waters, NNECo Chemistry Supervisor

  *E.-Laine, NNEco Radiation Protection Supervisor

. *W. Romberg, NNECo station Superintendent . G. Baskette, Dosimetry Laboratory Supervisor B. Robinson, Assistant Radiatio'n Protection Support Supervisor

  " Siegrist, Supervisor, Radiological Protection J. Sullivan, Health Physicist

G. Closius, QA/QC Supervisor i

i * denotes attendance at exit meeting.

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2.0 Status of Previously Identified ~ Items i 2.1 (Closed) Follow-up (245/83-04-01). Review TLD/PIC (pocket ion chamber) Discrepancy Reports. .The inspector' reviewed a sample of TLD/PIC dis-crepancy reports for 1985, and observed that the cause of the discrepancy.

, and the corrective actions taken were clearly stated on all reports .i reviewed. This~ item is closed.

' 2.2 (0 pen)' Follow-up (423/85-19-04) Status of procedures for start-up surveys. 'The licensee has identified the following to be incorporated into the start-up survey procedures:

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' measure neutron spectrum in various areas of containment to determine neutron spectrum factors; [

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evaluate actual instrument response to the expected response for subatmospheric containment conditions;

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develop. radiation' dose rate data base for pr'e-determined areas of containment at various power levels. Comaare. instrument response - and TLD response at these areas; ,'

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develop a program for~ surveying unsealed penetrations in the containment shield wall, and a means to clearly document the survey, results;

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evaluate the response of various-survey instruments and TLDs to N-16 . gammas;

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Perform and document shield surveys at the required power levels;

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Compare response of portable survey instruments to fixed area monitor , [ ,

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This item remains open pending completion of the start up survey procedures.

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1 2.3 (0 pen) Follow-up (423/85-19-06). Supplies of alpha count ratemeter The licensee has submitted a change to the FSAR, Chapter 12.5, and to Tables 12.5-1 and 12.5-2 to more accurately describe the-numbers and

types of instrumentation available at the Millstone site. This' item will remain open pending acceptance of the FSAR amendment by NRR.

' 2.4 (0 pen) Follow-up (423/85-19-07). Supplies of PICS per FSAR commitment As stated above, the licensee has submitted a change to the FSAR to more '

,  accurately describe the numbers of equipment available to Unit 3. This item will remain open pending acceptance of the FSAR amendment by NRR.

2.5 (Closed) Follow-up (423/85-19-09). Review procedures 4909 and 4905 for-revisions. The inspector reviewed the pertinent sections of both 4 procedures and determined that the procedures had been appropriately

revised to address the initial concerns raised. The licensee has addressed beta counting. efficiencies for counting swipes in a covered configuration and the calculation to determine alpha activity has been corrected in procedure SHP 4905. Procedure SHP 4909 now specifies which personnel decontamination tasks are to be performed by Health Physics and which tasks should be performed only by medical personnel. Also, the steps to decontaminate individuals has been revised to require medical supervision with more caustic method .0 Orcanization The responsibility for the Millstone dosimetry program is assigned to the j Radi'ation Protection Support Group under the site Health Physics Super-i visor. This department provides dosimetry. services to support Units 1, 2, and 3. Dosimetry processing is performed by the staff assigned to the j Supervisor, Radiological Protection in the Radiological Assessment Branch at the corporate office in Berlin, Connecticut.

' . 4.0 Selection and Qualification of Dosimetry Laboratory Personnel j The inspector reviewed procedure number 1.3, " Dosimetry Laboratory Training and Program," and selected records of dostmetry laboratory personnel. Position description for all personnel were available and

 ~ clearly defined. All personnel had met the minimum qualification for their position Corporate dosimetry laboratory personnel training and retraining records were reviewed. All personnel had met the initial training and retraining

requirements for the departmen .0 Facilities and Equipment

The . inspectors toured the facility used by the licensee for the i processing of personnel dosimetry. The licensee uses three Model 9100 Teledyne readers to process its whole body dosimeter Information ! e . <c-- ,,.y .- . . _ , , --, , . , . . , , - ~ , - . . . - - . - , - ~

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4 l l from the Model.9100 readers Is entered directly into an IBM series 1 i . computer which converts light output to dose via dose conversion factors and individual TLD response factors (similar to element correction-factors). The IBM series 1 prints out a hard copy of the TLD processing-results, which is reviewed by the staff in the Radiological Assessment , Branch. After the data review is completed, the.TLD processing results are manually inserted onto an IBM 370 computer.into the Helpore system, which provides dosimetry results to the M111 store site for personne The licensee uses the Teledyne calcium sulfate, dysprosium-doped (CaSO.: Dy) TLD for personnel monitoring of beta and gamma doses. The holder of the TLD'is designed to provide four individually shielded areas

to determine dose. The design is as follows:

Area Filtration (milligrams per square centimeter)

1 7 (mylar) i 2 300 (plastic) 1 3 >300 (aluminium, copper)_ 4 >300 (cadmium, copper) t.

I The licensee determines ~ deep dose using areas 3 and 4 of this dosimete Areas I and 2 are used to assign shallow dose. A cesium-137 calibration source is used to characterize response under each area of filtratio These response factors are evaluated every two year The licensee monitors neutron exposures by providing an additional TLD to the badge holder. The additional TLD consists of natural lithium fluoride blended into the CaSO.: Dy phosphor ('LiF/CaSO.:0y). The holder is mounted onto a belt for use as an Albedo dosimeter. Areas 3 and 4 of

the double card badge are used to measure neutron dose by subtracting the gamma dose from the CaSO.

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! The licensee uses lithium fluoride disks mounted in finger rings for.

! extremity monitoring. A Teledyne model.7300 reader is used to read the l disk Information is processed in the same manner as the whole body t badge Self-reading pocket dosimeters are assigned to workers to use to monitor

their doses during work activities. In addition,-the data from self-reading . dosimeters are recorded on radiation work permits (RWP) and used by the

 - ALARA group to determine the dose received during particular jobs.

The dosimetery laboratory is located ~away from the Millstone site. This i

' will ensure that dosimetry. processing will not be affected in the event of an emergency.

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6.0 Calibrations The licensee performs his own calibrations with a Cs-137 source (J. Shepherd Model 89), mounted in a J. L. Shepherd Model 78-2M Calibrator (dimension 16"x 25" x 16"), complete with a Series 154 Attenuator Syste The inspector observed licensee representatives performing a calibration and noted that a Victoreen R-chamber was used to measure the delivered exposure. The inspector discussed the calibration of the R-chamber with the lice'n'see and determined that each R-chamber was calibrated as require The readout device did not accurately indicate the delivered dose due to a narrow instrument scale covering a wide range of exposure. It appears that the R-chamber readout scale may contribute to additional systematic error during the calibration process. The inspector discussed with licensee representatives the total uncertainty associated with this cali-bration method. The licensee's cognizant individual was not available during this inspection and the licensee personnel present were unable to retrieve any studies or information clarifying the uncertainties assoc-iated with this method. The inspector stated that this matter will be re-examined during a future inspection. (245/85-23-01; 336/85-28-01; 423/85-47-01).

7.0 Quality Assurance / Quality Control The inspector discussed with the licensee the quality control program for the dosimetry laboratory. The licensee processes two badges pre-irradi-ated to a known dose for every 50 dosimeters' processed, as part of their laboratory QC program. A special. review group of the Radiological Assessment Branch reviews all data before it is entered into the Helpore system to check for anomalous data. A computer file is kept or all badges and readings to track faulty TLD performanc The Radiological Assessment Branch conducts monthly quality assurance audits of the dosimetry processing facility. . The inspector reviewed two monthly audits and found that the content of the audits addressed the performance of the readers and the TLDs using' the National Voluntary Laboratory Accreditation Program (NVLAP) criteri The licensee participates.in an interlaboratory comparison program with University of Michigan semi-annually for their neutron dosimetry and annually for accident dosimetr A trending program has been established by the corporate analyst for the dosimetry program on a quarterly basis. The inspector reviewed the Dosimetry Laboratory Trends Analysis Report for the first quarter of 1985 and'found that it contained extensive trending studies on the dosimetry used at the Millstone site. It appears that this trend analysis program will be a valuable tool for the licensee to use to measure adequate and deficient performance of the dosimetry.

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,. . 1 6 The Millstone site conducts a quality assurance program of dosimetry under j- station procedure HP 941/2941/3941, " Performance Audits for Personnel  ; i Monitoring Equipment." Under this procedure the licensee irradiates 50 l l' dosimeters to known coses and sends these dosimeters with the monthly per-sonnel badges'for processing'. The inspecto- examined selected records of j these ' spiked samples and found that for January, .1985. and May,1985, dis-i

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crepant data were identified for badges spiked with beta doses. Section 6.4 of this procedure states.that "if the reported results are unaccept- ' able, a written investigation shall be completed and filed." Licensee

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i j representatives present at the time of the inspection were unable to

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matter will remain unresolved pending further review by the NRC i (245/85-23-02; 336/85-28-02;.423/85-47-02).

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Section 5.1.2 of the procedure HP 941/2941/3941 describes. performance te.sts for self-reading dosimeters (PICS) in fields of high energy photons and fast neutrons. 'This data was also not available, and will be

, reviewed in a future inspection (245/85-23-03; 336/85-28-03; j 423/85-47-03).

The licensee sets out extra badges in various areas of the plant to monitor background conditions, especially in badge storage areas, such as

:  the Primary Access Point, and the North Access Point. These badges are

sent with the personnel badges and the spiked badges to the Dosimetry .

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l Processing laboratory. Site personnel track these blank badges and trend I the background readings in these-areas. However, this practice is not ~ described and controlled in any procedure. The licensee stated that they .

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will incorporate the use of these blank badges as another quality assur-  ! i ance measurement into Procedure HP 941/2941/3941. - This will be reviewed { in a future inspection (245/85-23-04; 336/85-28-03; 423/85-47-03).

j Dose Assessment 8.1 Minimum Reporta'le b Dose

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The inspector reviewed the following procedures to identify parameters to l

calculate the minimum reportable dose (MRD)

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l~ ' 4.8 Manual Calculation of Beta-Gamma Dose, Rev. 2, April-1985  : 4.9 Manual Calculation of Neutron Dose, Rev. 2, April 1985 i The inspector noted that the licensee did not apply the necessary

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confidence levels to the calculation of'the MRDs. Due to the absence of ! the cognizant individual, the inspector was unable to-obtain more i information. The inspector stated that the accuracy of the statistical

determination of the MRDs will be examined during a future inspection { (245/85-23-05; 336/85-28-05; 423/85-47-05).

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8.2' Dose Assessment

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A daily assignment of de'ep dose is entered into the Helpore system by , . station health physics prsonnel based on pocket ion chamber (PIC) i > readings. These dose assignments are replaced monthly by TLD deep dose

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readings. If the TLD readings and PIC readings differ by more than 125%

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on doses greater than 150 millirems, the Helpore system generates an Exception report, flagging any individuals with discrepancies between the ! TLD and PIC readings. The site dosimetry supervisor investigates all j Exception reports. All investigations are filed in the individual's l personnel dose fil l

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Extremity and neutron dosimetry is issued to personnel based on RWP requirements. Any neutron doses measured are added to the whole body ' , dos .0 Documentation and Recordkeeping The inspector reviewed the licensee's methods for documenting its dosimetry processing, dose assessment, quality control program, and personnel dose historie Licensee representatives stated that all raw

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data, dose records of dose assessments and personnel dose histories will i be maintained indefinitely.

The inspector reviewed the licensee's program for providing required

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termination reports for monitored individuals. ' Selected instances of - terminations of contractor and licensee employees were examined and in  ; j each instance, the required termination reports had been provide . No violations were identifie < ! 10.0 Environmental Dosimetery I The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring Network is operated by the NRC (Region I) to provide ~ continuous measurement of the ambient radiation levels around nuclear power plants,

  (70 sites) throughout the United States. Each site is monitored by j   arranging approximately 30 to 50 thermoluminescent dosimeter (TLD)

' stations in two concentric rings extending to about five miles from.the power plant. The monitoring results are published in NUREG-0837 '

quarterl ~ One.of the purposes of this program is to serve as a basis of comparison with similar programs conducted by individual utilities which operate

nuclear power plants. Therefore, four NRC TLDs are co-located with each licensee's TLD stations.

l During this inspection the monitoring results of co-located TLDs were

compared and the results are listed in Table 2. Table 1 describes the NRC TLD location-around the Millstone Nuclear Power Plant.

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All NRC exposures are normalized to a 90-day quarter and reported in units of milliroentgens (mR), and uncertainties are the total uncertainty (random and systematic uncertainties).

The licensee monitors the environmental radiation levels monthly using the EG&G TLD System (CaF 2 :Mn) and reports in units of microrcentgen per hour. The inspector converted the results to milliroentgen per 90 days and the results are shown in Table The NRC's monitoring results of the first quarter of 1984 are lower than the licensee's results. The low results were due to the high transit dose for the NRC dosimeters. It was suspected that the NRC's contractor did not handle control TLDs properl The NRC TLDs are placed about 10 ft. above the ground but the licensee's TLDs are placed 4 ft. above the ground. Although there are differences between the NRC and the licensee's programs, results are generally in good agreemen .0 Independent Performance Test The inspector arranged to have 50 of the licensee's personnel dosimeters ' sent to Idaho National Engineering Laboratory for a test of their performance. The results of this performance test will be provided in a future inspection repor .0 Unresolved Item Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during this inspection is discussed in Paragraph .0 Exit Interview The inspector. met with licensee representatives (denoted in Section 1) on August 9, 1985. The inspector summarized the purpose, scope, and findings of the inspection. At no time during this inspection was written material provided to the licensee by the inspector.

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Table Co-location of the TLD Station NE Millstone location Description 4 11 ENE, 60 , 1.7 m New London Country Club 5 10 E, 85 , 1.3 m Pleasure Beach Fire Station 11 SSB SW, 232 , 2.5 m Old Black Point Road 12 54B WSW, 256 , 2.4 m Billow Road Black Point

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_ --__- . _ _ _ . TABLE 2 - ENVIRONMENTAL MONITORING RESULTS (mR/90 daysj T LD Sta_t i on: NRC Station _ Number / Millstone Station t{ umber e Monitorina Period 4/11 5/10 11]fdn 1 2 / 584 !} 1st QTR 1983 NRC( 1 ) . 11.8 1 .0 1 .2 1 .1 1 Millstone (2) 16.6 1 .4 i .7 1 .2 1 nd QTR 1983 NRC 15.4 1 .4 1 .1 1 TLD Missing Millstone 16.4 1 .9 1 1,8 15.8 1 .1 1 rd Q1R 1983 NRC 12.5 1 .1 1 .2 i .8 i Millstone 17.9 1 .3 1 .6 1 .2 1 th QTR 1983 NRC 16.8 1 .5 1 .1 1 .2 1 Millstone 16.7 1 .9 1 .6 t .0 i 1.8 i 1st QTR 198t4 NRC ( 3 ) 9.7 1 .0 1 .5 1 .8 i Millstone 16.7.1 .5 i .0 1 .4 2 nd QTR 1984 NRC 18.1 1 .5 1 .6 1 .1 1 Millstone 17.2 1 .9 1 .9 1 .1 1 rd QT R 1984 NRC 17.6 1 .0 2 .5 1 .7 1 3.6 , Millstone 17.6 i .7 1 .4 i .7 1 th QTR 1984 NRC 17.0 1 .7 1 .7 i .5 i Millstone 19.1 1 .9 1 .7 1 .8 1 st QTR 1985 NRC 18.3 1 .8 1 .1 1 .8 1 Millstone 17.9 1 .9 1 .9 1 .4 1 (1) NRC: mR i total uncertainty. Panasonic TLD System (CaSO:Tm), Monitoring Quarterly

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TLDs are placed about 10 ft. above the ground.

i (2) Millstone; mR i total Uncertainty (Reporting Unit is uR/hr. All results were converted to mR/90 days).. EC&G TLD System (CaFgMn), Moni toring Monthl TLDs a re placed 4 f t. above the g roun (3) Low results were due to the high transit dose. The transit dose was 11.5 mR/90 day . S

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