IR 05000272/1994005
| ML18100A960 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/14/1994 |
| From: | Bores B, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18100A959 | List: |
| References | |
| 50-272-94-05, 50-272-94-5, 50-311-94-05, 50-311-94-5, NUDOCS 9403250060 | |
| Download: ML18100A960 (10) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No /94-05 50-311/94-05 Docket Nos. 50-272 50-311 License Nos. DRP-70 DPR-75 Licensee:
. Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge. New Jersey Facility Name:
Salem Nuclear Generating Station. Units 1 and 2 Inspection At:
Hancocks Bridge. New Jersey Inspection Conducted:
February 14-18. 1994 Inspector:
Approved by: ~
B. B
, C "ef Facilities Radiation Protection Section, Facilities Radiological Safety and Safeguards Branch, Division of Radiation Safety and Safeguards
!ldJi date
~)J&l/~'f date Areas Inspected: An announced inspection of the radiological controls program at the Salem Nuclear Generating Station was conducted. The areas reviewed included action on previous inspection findings, air sampling, respiratory protection, and bioassay program Findings: The inspection revealed use of respiratory protection equipment commensurate with the relatively low concentrations of airborne radioactivity experienced at Salem Station, and a very low level of internal personnel exposures. A few areas for potential improvement in the air sample and bioassay programs are discussed in Sections 4.1 and 6.2 of the enclosed inspection report. No safety concerns or violations of NRC regulatory requirements were identified during the inspectio ::;.
PDR ADOCK 05000272 ;1:
. PDR
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DETAILS Individuals Contacted Public Service Electric and Gas Company
- T. Cellmer, Radiation Protection/Chemistry Manager - Salem
- R. Chranowski, Salem Technical Engineer/Salem Technical Department
- W. Grau, Station Licensing Engineer/PSE&G Licensing
- * J. Hagan, Vice President of Nuclear Operations/General Manager - Salem Operations
- E. Katzman, Principal Engineer - Radiation Protection/Chemistry
- M. Prystupa, Radiation Protection Manager - Hope Creek
- D. Ruyter, Senior Supervisor Radiation Protection
- M. Simpson, Senior Staff Engineer, Nuclear Services
- J. Wray, Radiation Protection Manager - Salem NRC Personnel * C. Marschall, Senior Resident Inspector
- Denotes attendance at the exit meeting on February 18, 1994.
The inspector also contacted other licensee personnel during the course of the inspectio Purpose This inspection was an announced safety inspection of the Salem Nuclear Generating Station personnel internal exposure control progra.0 Previously Identified Items (Closed) Inspector Followup Item (50-272/93-22-01)
This was an open issue regarding the proper personnel response to an electronic dosimeter in the alarm mode. Appropriate training was provided, however there had been no procedural documentation that specified the required actions to be taken. The inspector reviewed Salem Procedure NC.NA-AP.22-0024(Q), Revision 3, and noted that the procedure now provided the individual with the responsibility to leave the work area immediately and notify HP if the electronic dosimeter alarms. This item is closed.
3 (Closed) Inspector Followup Item (50-272/93-22-03)
During the previous Salem Unit 1 refueling outage, a worker dressed in an air-supplied plastic hood (bubble suit), lost air supply to the suit and HP technicians responded by cutting the worker out of the bubble suit and emergency assistance was provided in transporting the worker to a local hospital. The inspector determined that although the licensee had direct voice communication with the worker and had
- constant HP coverage of his activities, no one was stationed to continuously monitor the air supply pressure as required by the respiratory protection program procedur There was no federal requirement for continuous air supply pressure surveillance, however, the licensee was reviewing existing station procedures for suitabilit During the current inspection, the inspector reviewed the licensee's resolution of this issue. Although not a federal requirement, the licensee chose to use the Immediately Dangerous to Life or Health (IDLH) standard for any use of the air-supplied bubble suit (as specified in 29 CFR 1910). The licensee's initial corrective actions included revision of Procedure SC.RP-TI. ZZ-0403(Q) to specify the requirement for continuous surveillance of the air supply pressure at all times while a worker is using an air-supplied bubble suit. In addition, the licensee has decided to procure a new air supply distribution manifold which includes a backup air bottle in order to supply the necessary emergency air upon loss of the primary air supply and would allow the worker time to egress from the bubble suit safely. These actions are an improvement to the current program and this item is considered close.0 Air Sampling The licensee utilized a broad-based program for sampling of airborne radionuclide This consisted of continuous monitoring of the containment atmosphere and plant exhausts, local area continuous air monitors (CAMs), stationary grab samplers, and lapel air samplers that were worn by workers. The last two types of air samplers were utilized by the licensee to a large extent during refueling and maintenance outages. During standard plant operations for normal surveillance activities, the first two air monitor types were used. The containment atmosphere and plant exhaust monitors read out in the control room and were provided with alarms set to prevent the offsite dose from exceeding regulatory limits. To alert onsite personnel of any unexpected airborne radiological hazards during plant operations, the containment atmosphere monitors were checked by HP personnel every four hours for indications
- of deteriorating plant conditions. Also, CAMs were used in the accessible areas of the plant to sample particulate air activities and alarm when the focal air concentrations exceeded a preset alarm level. Stationary grab samplers were also used in specified areas of the plant to sample particulate and iodine activit Through plant tours, the inspector determined that there were 15 Eberline AMS-3 CAMs and seven Radeco HD-28 low volume air samplers (stationary grab samplers)
in service in representative locations in the radiological controlled areas to monitor
- the air activity during routine operations. Each CAM was set to alarm at approximately 1200 counts per minute above background. According to Procedure SC.RP-TI.ZZ-0601(Q), Revision 3, this value was based on the amount of radioactivity that would collect in one hour representing a concentration of lE-9 uCi/cc. Further procedural guidance states that an airborne concentration which causes an increase of 1000 counts per minute within 15 minutes is approximately equivalent to. l derived air concentration (DAC). The inspector determined that the
- 1000-count per minute increase over 15 minutes corresponded to 0.3 DAC, which also corresponds to the weekly limit for defining an airborne radioactivity area. The inspector determined that the licensee provided sufficient guidance to allow qualified HP personnel to determine changing air conditions and CAM alarms should be indicative of an airborne radioactivity area. The inspector was satisfied that all major accessible plant areas were monitored or routinely sampled and that appropriate control levels were in effec The inspector reviewed recent air sample data for selected time periods during the previous refueling outage. During operating status the licensee averaged 8 air samples per day and during peak refueling outage work, averaged approximately 36 air samples per day. All air samples reviewed indicated relatively low airborne radioactivity concentrations (S 0.1 DAC). These air samples included those taken during pressurizer system work and during steam generator primary system work activities, which included shot peening of the steam generator U-tubes. Apparently contamination control measures were effective in mitigating the generation of airborne contamination conditions during these primary system maintenance activities. The licensee's efforts to control the contamination source to prevent internal exposure of the worker during the Salem Unit-1 1993 refueling outage was effective and commendabl Air Sample Measurement Laboratory The inspector reviewed the air sample counting laboratory calibrations and quality control techniques in accordance with ANSI N42.14 and N323 standard practice The licensee utilized a gross beta-gamma count determination for initial screening of air samples. The Eberline BC-4 counters were calibrated within the last six month An appropriate technetium-99 source that was traceable to the National Institutes of Standards and Technology (NIST) was used to determine the beta calibration. The counting laboratory also has capability for isotopic analysis of gamma-emitting isotopes, which was used for DAC determinations. The laboratory contained six lithium-drifted germanium detectors, each of which was calibrated within the annual frequency utilizing a mixed isotope source, certified by NIST, for each of the collection media. The calibration data and quality control charts were reviewed by the inspector and found to be of excellent qualit *
The inspector reviewed the DAC calculation method used by the counting laborator The inspector also reviewed the latest offsite laboratory analysis of Salem smear samples as given belo Isotope Fraction Radiation DAC1
% ofDAC Fe-55 30.8%
electron capture 2E-6 Ni-63 15.5%
66 keV beta ma E-7 *H-3 3.3%
19 keV beta ma E-5
Co-57 0.4%
122 keV gamma 3E-7
Sb-125 2%
428 keV gamma 2E-7 Cs-137 5.5%
662 keV gamma 6E-8 Zr-95 0.2%
757 keV gamma 5E-8 Nb-95 0.5%
766 keV gamma 5E-7
Co-58 27.4%
835 keV gamma 3E-7 Co-60 10.4%
1173 keV gamma lE-8 7 keV gamma Cs-134 3.4%
1465 keV gamma 4E-8 From the isotopes listed, approximately 50% of the radioactivity was represented by non-gamma emitting isotopes, which were not measurable by the licensee's gamma spectroscopy analysis and were not included in the licensee's DAC reporting. The significance of this was low because the low energy beta emitting isotopes and Fe-55 represent only a small fraction of the DAC. The inspector determined that the licensee has not accounted for approximately 2.7% of the DAC value based on the station smear sample analysis data. It is considered an area for potential improvement that the non-gamma emitting isotopes have not been considered in the DAC determinations. However, as previously discussed, the licensee has a very good history of low activity in air samples, therefore, this additional DAC amount would not have resulted in any internal exposure difference to the workers at Salem Statio The licensee has agreed to review this issue and determine if any refinements to the program are necessar. 0 Respiratory Protection The inspector reviewed the licensee's respiratory protection program by conducting interviews with licensee representatives and through the review of procedures and various licensee records. This review was made with respect to 10 CFR 20 requirements and NUREG-0041, ANSI Z86.1-1972, and ANSI Z88.2-1991 guideline As derived from the licensee's "Air Sampling Program Technical Basis", Revision ~
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The licensee maintained an effective respiratory protection equipment washing, repairing and testing facility. These services were provided for the Salem respiratory protection program by the Hope Creek Station. A dishwasher was used with detergent and a sanitizing agent to clean and disinfect the respirator Respirators were dried in a controlled temperature drying cabinet and each was inspected for.defects and repaired as necessary. Procedures required air particle
- penetration testing for each respirator prior to reissue. All used respirator filters were externally decontaminated and subjected to an air particle penetration and filter buildup test prior to reissuance. The inspector reviewed the technical bases and adequacy of the respirator test procedures and found them adequat Federal regulations state that only respiratory protection devices that were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration (NIOSH/MSHA) may be used. The licensee currently uses the following respiratory protection devices and the inspector verified the NIOSH/MSHA certifications of eac MSA Ultravue respirators, NIOSH/MSHA approval TC-21C-150 MSA Ultra filters, NIOSH/MSHA approval TC-21C-150 MSA Ultratwin, NIOSH/MSHA approval TC-21C-188 MSA Twin filter, Type H, NIOSH/MSHA approval TC-21C-125 The licensee has experienced a decline in respirator use over the last two years. In 1991, approximately 2050 respirators were issued during two refueling outage During 1992, approximately 620 respirators were issued during two refueling outage In 1993, during one refueling outage, 81 respirators were issued. Approximately 20 full face respirators were currently available for immediate issue with an additional 900 in storage. The licensee indicated that the decline in respirator use is the result in part by the new 10 CFR 20 regulations, which base internal exposure on annual limits, and in part, by the effective application of engineering controls to control contamination, which has lessened the need for respiratory protection at Salem Statio The inspector reviewed the breathing air supply controls and air quality testing data provided by the licensee. The station breathing air system is supplied by three oil-lubricated air compressors (common to both units). The licensee also utilized an oil-lubricated compressor for the filling of breathing air bottles. The station utilized a Biosystems Travel Panel 50 in the supplied air system to protect the worker against elevated carbon monoxide levels. This equipment contains a carbon monoxide detector and alarm contained in an air distribution manifold modul The inspector reviewed laboratory testing results of station breathing air and self-contained breathing air (SCBA) bottle air supply systems. All air supply sources
were regularly sampled on at least a six-month basis. The inspector revi~wed sample analysis test results for both air supply compressor systems and verified that the six-month air quality determination met the Grade D (as defined by the Compressed Gas Association) air certification requiremen The inspector reviewed the supplied air hoses, distribution manifolds, and regulators used to support an airline breathing system. Appropriate storage and controls of this
- equipment were exercised by the licensee. All carbon monoxide detectors and air regulators were routinely calibrated using Draeger tubes and a secondary standard, respectively. No discrepancies were noted with these practice The inspector reviewed the administrative controls to ensure only qualified.individuals were issued the appropriate respiratory equipment for which they were qualified to use. The respirator training, respirator fit testing, medical examination, and whole body count annual completion dates were input to a computer network database system, the Personnel Radiation Exposure Monitoring System (PREMS), which was used by HP personnel to determine whether a worker was qualified for issuance of a respiratory protection device. Respirators were stored at the HP access point inside the HP instrument issue room and a PREMS terminal was also available at this issue point for reference of respirator qualification. Adequate precautions were taken to ensure proper issuance of quality respiratory protection equipmen The fit testing of individuals is performed using a Portacount instrument to measure the protection factor of the respirator wearer while performing seven different physical exercises. The acceptance criterion is a minimum protection factor of 500 during each of the seven tests. The licensee has two Portacount instruments that are calibrated annually by the manufacturer on a rotational basi The inspector witnessed the storage condition of each of the following emergency respirator kits on site to ensure emergency response capability was maintaine emergency response SCBA units located in the control room 10 SCBA units located at the HP control point
6 SCBA units located on the 84-foot elevation of the Service Building 6 SCBA units located on the 64-foot elevation of the Service Building At each location the air bottles indicated full pressurization and the respirator equipment was ready for use. A check sheet in each emergency kit indicated that monthly inspections had been carried out regularl.0 Internal Exposure The inspector reviewed records provided by the licensee and determined that during 1993, Salem station recorded a total of 273.4 maximum permissible concentration
hours (MPC-hrs). The maximum for one individual was 17.4 MPC-hrs for that yea There were 64 individuals with recorded exposure. The average exposure of these individuals was 4.3 MPC-hrs and the median value was 3.2 MPC-hrs. The licensee indicated that there have been no internal exposures recorded for 1994 at the time of this inspection. These values reflect very low exposures compared with the 1993 federal limit of 520 MPC-hrs per quarter per individua.1
- Internal Exposure Tracking The inspector reviewed the licensee's DAC-hr tracking system through a review of procedures and through discussions with the licensee. The licensee begins tracking at 2. 0.5 DAC-hrs per entry and any individual who accumulates 2. 10 DAC-hrs per seven days requires a whole body count. Any whole body count and resulting dose assessment that results in 2. 50 mrem (or 125 DAC-hrs) requires the internal exposure to be included in an individual's dose of record. The federal regulations require recording of internal exposure for those individuals expected to receive 10%
or higher of the annual exposure limit (2000 DAC-hrs), which corresponds to 200 DAC-hrs. The licensee's action level and dose recording criteria were found to be in accordance with current regulation.2 Internal Exposure Measurement and Assessment The inspector reviewed the licensee's internal exposure assessment/bioassay program, through licensee demonstrations of the whole body counters' calibration methodology, through a review of applicable procedures and calibration records, and through discussions with knowledgeable station personnel. The inspector's review was with respect to the criteria contained within 10 CFR 20, ANSI N343-1978, ICRP 26 and 3 The licensee utilized two whole body counting systems for the measurement of internally deposited gamma-emitting radioisotopes in the body. The principal counting system was a standup, two-sodium iodide (thalium) detector system, the Canberra Fastscan whole body counter. The secondary counting system was a standup geometry, single intrinsic germanium detector system, the Canberra Accuscan whole body counter. The inspector reviewed the calibration setup utilizing a tissue-equivalent phantom with vials of liquid containing National Institute of Standards and Technology (NIST) traceable sources. The inspector reviewed the results from the latest calibration of the whole body counters. The Canberra Fastscan whole body counter was calibrated within the last year on October 9, 1993. The Canberra Accuscan whole body counter was last calibrated in 1989. The inspector questioned why the germanium detector whole body counter was not kept in calibration on an annual basis as was the Fastscan whole body counter. The licensee indicated that there has not been a need for this whole body counter. The internal exposure controls
associated with the operation of Salem and Hope Creek Stations have not required the use of an investigative whole body counte The inspector reviewed with the licensee the results of the latest offsite laboratory analysis of Salem's contamination smear samples from the perspective of detection of personnel internal contamination. (See table on page 5 of this report.)
The inspector questioned the licensee as to the limitations of the Fastscan sodium-iodide (thallium) detector system to correctly identify the above mixture of radioisotopes. The licensee stated that the Fastscan instrument was able to correctly identify gamma energies of approximately 70 keV difference. Based on the primary radiations emitted, there are a number of gamma emitting nuclides that would have overlapping gamma spectra and therefore, which may not be correctly identified by the sodium-iodide detector whole body counter. The inspector agreed that use of the Fastscan whole body counter as a screening instrument (i.e., used to determine whether or not a worker has internally deposited radioactivity) was valid and that was the principal use of this detector by the licensee. The licensee agreed to review the limitations of the Fastscan whole body counter when used beyond the screening mode for determining internal exposures. The licensee also agreed to maintain annual calibrations of the Accuscan whole body counter to provide the capability to assess uptakes of the gamma emitting radioisotopes found at the statio Energy and efficiency calibration data were completed for the Fastscan whole body counter and were used to develop appropriate quality control (QC) charts to plot daily source counts within statistical accuracy limits of +2 standard deviations. The inspector reviewed the latest QC charts and verified that the licensee has been performing daily source count verifications of the Fastscan whole body counter when in us The inspector questioned the licensee regarding the methodology of determining internal exposures. The licensee currently relies on the Canberra Abacos-Plus computer software to identify the detected radioisotopes, to calculate the amount of radioactivity, and to calculate the internal exposure based on an acute intake even The internal exposure calculation feature is currently utilized by the licensee for internal exposures not to exceed 25 mrem. The software has a disclaimer that the internal exposure calculation feature should not be used for record dose assessment purposes, and the licensee has not used it for that purpose. The licensee did agree to provide a technical review of the software and investigate its limitations and evaluate its application for site specific radioisotopes and for incidents other than single acute intake For internal exposures greater than 25 mrem, the licensee's procedure directs the radiation protection supervisor or engineer to determine the need for additional bioassay measurements, however, no method was specified as to how an internal dose
assessment would be calculated. The licensee stated that the past history at Salem Station suggests that internal dose assessments > 25 mrem may not be needed, however, the licensee agreed that some framework should be proceduralized to provide some guidance for conducting an internal dose assessment should the need aris.0 Exit.Meetin The inspector met with licensee representatives at the conclusion of this inspection, on February 18, 1994. The inspector reviewed the inspection findings and the licensee acknowledged the results.