IR 05000277/1979007
| ML19209A832 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/26/1979 |
| From: | Crocker H, Neely D, Serabian J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19209A820 | List: |
| References | |
| 50-277-79-07, 50-277-79-7, 50-278-79-06, 50-278-79-6, NUDOCS 7910050456 | |
| Download: ML19209A832 (1) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-277/79-07 Report No.
50-278/79-06 50-277 Docket No.
50-278 DPR-44 C
License No.
DPR-56 Priority Category C
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Licensee:
Philadelphia Electric Comoany 2301 Market Street Philadelphia, Pennsv1vania 19101 Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3 Inspection at: Delta, Pennsylvania Inspection conducted: Feb ary 13-16, 1979 2h7f Inspector.
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,/
- D. R. Neely, Radiation Specialist
' date signed
.k.
3f24-79 f. A. SeraD1an, Radiation Specialist (Intern)
dat4! signed
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date signed d b t/ 79 Approved by-j M
A H. W. Crocker, A'cting Chief, Radiation
/ ' date' pgned Support Section, FF&MS Branch Inspection Summary:
Inspection on February 13-16,1979 (Combined Reoort Nos. 50-277/79-07 and 50-278/79-06 Areas Inspected: Routine, unannounced inspection by two regional based inspectors of the Radiation Protection Program during operation including: organization, licensee audits, training, instruments and equipment, exposure control, posting, labeling and control of radioactive materials, notifications and reports, and licensee action on previous inspection findings.
Upon initial arrival at the cite on February 13,1979 at 3:20 p.m., and at other times during the inspection, areas where work was being conducted were examined to review radiation safety control procedures and practices.
The inspection involved 50 inspector-hours onsite by two regional based inspectors.
Results: Of the nine areas inspected, no items of noncompliance were found in eight areas; one apparent item of noncompliance was found in one area (Infraction -
failure to perform an evaluation to determine compliance with 10 CFR 20.101, paragraph 10.a).
Region I Form 12 1127 057 p3ooso rs (Rev. April 77)
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DETAILS 1.
Persons Contacted
- W. T. Ullrich, Station Superintendent
- R. S. Fleishman, Assistant Stat.on Superintendent
- M. Sullivan, Health Physics Staff Assistant N. Gazda, Support Supervisor K. Mandel, Assistant Auditor, QA R. MacAllister, Dosimetry and Bioassay Supervisor J. Valinski, Health Physics Supervisor Tha inspector also talked with and interviewed several other licensee employees, including members of the health physics staff (station and contractor), and reactor and plant equipment operators.
- denotes those persons present at the exit interview on February 16, 1979.
2.
Licensee Action on Previous Inspection Findings
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(Closed) Noncompliance (277/77-18-02): Failure to detennine airborne concentration of radioactive material. The inspector verified that the licensee had designed and mounted a new sampling head (filter holder) on the grinding platform.
In addition, the inspector verified that the licensee has established a method which covers the control of resurveys for jobs where the potential for airborne radioactive contamination exists.
(Closed) Inspector followup item (277/77-25-02): Licensee to re-evaluate contamination area identification to eliminate confusion.
A licensee representative indicated to the inspector that they are continuing to use the magenta and yellow tape (Rad tape) for estab-lishing contaminated areas.
The licensee representative further stated that emphasis is placed on establishing this type of barrier in order to prevent confusion on the part of the worker.
During tours of the controlled areas the inspector observed that contaminated areas appeared to be discretely marked.
(Closed) Inspector followup item (277/77-25-04): Licensee to evaluate and develop a Radiological Incident reporting system.
The licensee has revised the form used to record and evaluate radiological incidents.
The inspectors reviewed most of the Radiological Incident reports for 1978 and determined that the licensee appears to take corrective action as needed or required.
1i27 OS8
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(Closed) Inspector followup item (278/77-DN-01): Review qualifications of newly assigned Radiation Protection Manager (RPM).
The inspector reviewed the qualifications of the Engineer, Health Physics, the individual currently assigned to the active position of RPM, and detennined that he meets the requirements of ANSI N18.1 (1971) Section 4.4.4.(Details, paragraph 3).
(Closed) Noncompliance (278/77-06-01): Failure to post a High Radiation Area.
The inspector verified that the licensee had developed a pro-cedure for the transport and storage of radioactive waste.
During tours of the radwaste area and other controlled areas of the plant the inspector observed that High Radiation Areas were properly posted.
(0 pen) Inspector followup iten (277/77-30-01; 278/77-30-01): Review Health Physics Training Program (Details, paragraph 4).
3.
Radiation Protection Orcanization The inspector reviewed the current organizational structure against the requirements of Technical Specification (T/S) 6.2.2, " Facility Staff."
T/S 6.2.2 states in part, "The facility organization shall be as shown on Figure 6.2.2 and...."
The current radiation protection organizational structure is shown below.
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Plant Superintendent lAsst. Plant Superintendent Enoineer Technicial Enoineer - Health Physics Cl erk.
Health Physics Staff Assistant Health Physics Supervisor Supoort Supervisor Unit 2 Area Unit 3 Area Dosimetry and Misc. SupportF-Supervisor Supervisor Bioassaf Supr.
t Technicians Technicians Routine Work Supervisor Whole Body Counter Tech.
Technicians 1127 059 Res piratory Protection
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During review of the radiation protection organization the inspector utilized the following references:
a.
Letter dated February 28, 1977 from George Lear, Chief, Operating Reactors Branch #3, Division of Operating Reactors to Edward G.
Bauer, Jr., Esquire, Vice President and General Council, Philadelphia Electric Company, b.
Letter dated April 29, 1977, from J. A. Hankins, Philadelphia Electric Company to George Lear, Nuclear Regulatory Commission.
c.
Letter dated January 4, 1978 from J. A. Hankins to George Lear.
In reference a. above, the licensee was requested to detennine if the individual performing the function of Radiation Protection Manager (RPM)
meets the requirements of Regulatory Guide 1.8, September, 1975.
In reference b. the licensee responded to the requests in reference a.
The reference b. response stated that the present RPM did not meet the requirements listed in Regulatory Guide 1.8, but would meet the requirements in May 1979. At such time or in the event he was replaced or reassigned, a Technical Specification amendment would be requested which would incorporate the requirements of Regulatory Guide 1.8 for the RPM.
Reference c. discusses proposed improvements to the Peach Bottom radiation protection program.
Based on consultant recommendations, the licensee reorganized the Health Physics and Chemistry Group. The reorganization involved separating the health physics responsibilities from the chemistry responsibilities and placing these areas under separate supervision.
In order to make the change it was necessary to move the existing RPM to supervise the Chemistry Group and assign a new supervisor to be responsible for the radiation protection program.
Reference c. indicated that the newly assigned supervisor - Health Physics (performing under title of Engineer - Health Physics as shown above) would attain the required qualifications defined in Regulatory Guide 1.8, September 1975, in June of 1979.
At that time or in the event he is reassigrtd or replaced, a Technical Specification amendment will be requested to incorporate the requirements that the RPM have the qualifications listed in Regulatory Guide 1.8, September 1975.
The inspector will review the qualifications of the individual performing as Radiation Protection Manager against the requirements of Regulatory Guide 1.8 at such time when the requirement has been incorporated into the Unit 2 and 3 Technical Specifications.
1127 060
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The inspector noted that Figure 6.2.2 of T/S 6.2.2 does not show that the position of Engineer - Health Physics and Chemistry has been re-defined.
The inspector noted that the current radiation protection organizational structure is slightly more conservative than that shcwn in Figure 6.2.2 in that the management and implementation of the radiation protection program has been assigned to one particular
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person whose sole responsibility is to carry out that function.
Technical Specification 6.3, " Facility Staff Qualifications," requires in Section 6.3.1 that each member of the facility staff shall meet the minimum qualifications of ANSI N18.1-1971 for comparable positions.
The inspector reviewed the qualifications of the radiation prote dion supervisory staff currently assigned to the positions shown above, against the criteria in ANSI N18.1-1971.
The inspector determined that the individuals meet or exceed the minimum requirements of ANSI N18.1-1971.
The position of radiation protection technician shown above was also reviewed against the criteria in ANSI N18.1-1971.
The positions of technicians are comprised of both Philadelphia Electric (PECo) personnel and vendor supplied health physics personnel.
Licensee representatives indicated that there are a total of 18 employees (of PECo) assigned as health physics technicians at the Peach Bottom facility.
Of these, 17 individuals are classified as
"C" technicians.
The re-maining individuals will advance to "C" rating in April 1979.
The inspector noted that at this time none of these individuals meet the requirements of ANSI N18.1-1971, Section 4.5.2, which defines the requirements for individuals performing in responsible positions.
Licensee representatives indicated that seven (7) of the individuals would meet the requirements of ANSI N18.1-1971 in September 1979 and ten (10) individuals would meet the requirements in May 1980.
The inspector stated that the qualifications of these ir, ividuals would be reviewed during subsequent inspections.
The inspector determined that the licensee, in the interim, fills the position of radiation protection technician with approximately 17 (vendor supplied) ANSI N18.1-1971 qualified individuals.
No items of noncompliance were identified.
4.
Licensee Audits Unit 2 and 3 Technical Specifications (T/S) 6.5.2.8 states in part,
" Audits of facility activities shall be performed under the cognizance of the OSR Committee.
These audits shall encompass:
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a.
The conformance of all facility operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per year.
b.
The performance, training and qualifications of the entire facility staff at least once per year and...."
Unit 2 and 3 Technical Specifications 6.5.2.10.c states, " Audit reports encompassed by Secticn 6.5.2.8 above, shall be forwarded to the Vice President, Electric Production and to the management positions responsible for the areas audited within 30 days after completion of the audit.
The inspector requested licensee representatives to provide the audit records for calendar year 1978 which applied to the above listed requirements with respect to the radiation protection program.
Licensee representatives provided the inspector with a copy of an audit report dated January 23, 1979.
According to the report the audit was done by a consultant during December 1978.
A licensee representative indicated that the audit was intended to meet the requirement of T/S 6.5.2.8.a.
The inspector stated that it was not clear whether the requirement of T/S 6.5.2.8.a was met based on a preliminary review of the audit report.
The inspector stated that he would have to review the OSR Committee audit procedure and discuss with the audit chairman the text of the audit performed in order to determine whether the requirement of T/S 6.5.2.8.a was met.
The inspector asked to see the OSR Committee audit which was related to the requirements of T/S 6.5.2.8.b, specifically, audits of performance, training and qualifications of the facility staff.
Licensee repre-sentatives were unable to provide the audit reports to the inspector by the close of the inspection.
Licensee representatives stated that the OSR Committee audit procedure and audit report pertaining to T/S 6.5.2.8.b would be forwarded to the Region I office for the inspector's review.
In regard to T/S 6.5.2.10.c, the inspector asked licensee representatives if they could provide the dates when the audit reports were transmitted to the Vice President, Electric Production, and to the management positions responsible for the areas audited.
Licensee representatives indicated that the individual responsible for the OSR Committee audits could not be reached at the time of the inspection, but that the requested information would be obtained and forwarded to the inspector.
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The inspector stated that the above matters would be considered un-resolved pending review of the audit recorts and reporting period.
(50-277/79-07-01; 50-278/79-06-01)
5.
Training Unit 2 and 3 Technida! Specifications 6.4 " Training," states in part in Section 6.4.1, "A retraining and replacement training program for the facility staff shall be maintained under the direction of the Station Superintendent and shall meet the requirements of Section 5.5 of "lSI N15 >-1971...."
The inspector reviewed the training program for members of the radiation protection staff against the following criteria:
a.
Replacement Training, ANSI N18.1-1971, Section 5.5.2 Section 5.5.2 states in part, "Special training programs for replacement personnel should include theory, systems, operating procedures, emergency procedures, radiation protection and other such subjects which are consistent with the positions involved and...."
The inspector discussed the replacement training with licensee representatives and learned that no formal replacement training program existed at the facility at the time of the inspection.
The Assistant Training Coordinator indicated that a formal training and replacement training program was being drafted which describes the entire program for training of permanent radiation protection technicians. This draft is expected to be presented to the Plant Superintendent in the very near future for his review.
The inspector discussed the previous training program which approximately 16 radiation protection technicians participated in during the last 18 months at the Peach Bottom facility.
The Assistant Training Coordinator indicated that two separate programs were initiated and that 17 individuals had completed those programs satisfactorily and subsequently were assigned to work in the plant under direct supervision (on-the-job training)
in order to apply what they had learned in the classroom sessions.
This would enable them to gain " hands-on experience." The inspector asked if the training material and records associated with the above mentioned training program were available for review.
The Assistant Training Coordinator stated that it would take several hours to gather the training material becaust the documents and records were stored in the Unit 1 area.
The inspector stated that the training material and records would be reviewed during a subsequent inspection.
I127 063
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Regarding future training programs the Assistant Training Coordinator indicated that a fonnal training program for radiation protection technicians was scheduled to begin about March 12, 1979 and be comp ~ieted six months later.
The in-spector reviewed the proposed training program and found that the subjects which would be covered appeared to meet the requirements of ANSI N18.1-1971, Section 5.5.2.
The inspector stated that the training program planned for March 1979 would be further reviewed during a subsequent inspection.
Licensee representatives indicated that training records and associated documents would be available for review.
b.
Retraining, ANSI N18.1-1971, Section 5.5.1 The inspectors discussed the retraining program for radiation protection personnel with licensee representatives. The inspector stated that he could not establish whether a formal retraining program existed which meets the requirements of Section 5.5.1 of ANSI N18.1-1971.
The inspector noted that the retraining was required for all members of the radiation protection organization.
Licensee representatives indicated that they would review their program to determine if they are meeting the requirement of Section 5.5.1.
The inspector stated that this matter is considered unresolved pending further review of the retraining programs that are in effect at the facility.
(50-277/79-07-02; 50-278/79-06-02)
6.
Instruments and Eouipment The inspector reviewed the licensee's inventory of portable radiation monitoring instruments assigned to the Peach Bottom facility.
The inspector determined that the licensee has an adequate supply of portable instruments in service to support the radiation protection program.
The instruments shown on the licensee's inventory appeared adequate to measure the types of radiation present at the facility.
The inspector examined calibration records for the portable radiation monitoring listed on the inventory sheets. The calibration records reviewed covered the period January 1, 1978 through December 31, 1978.
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The inspector noted that neither the Unit 2 or 3 Technical Specifi-cations nor any radiation protection procedure developed in accordance with T/S 6.8 or T/S 6.11 had provisions incorporated that reauired that portable radiation monitoring instruments be calibrated 'within a specified interval.
The instruments which currently are required to be calibrated at a specified interval are the friskers and portal monitors. The inspector noted that the licensee routinely calibrates all radiation monitorina instruments within a six month interval.
Licensee representatives stated that they would incorporate into the radiation protection procedures the requirement that all portable radiation monitoring instruments be calibrated at intervals not to exceed six months.
Licensee representatives stated that the additional provisions to the procedure would be accomplished within 90 days.
No items of noncompliance were identified.
7.
Posting, Labeling and Cor. trol of Radioactive Ma'.erial The inspector toured the facility several times during the inspection to observe compliance with the following requirements:
Area Requirement Establishing and Posting HP0/CO-ll Radiologically Controlled Areas Identification and Regulation HP0/C0-14 of Tools and Equipment in Controlled Areas Transport and Temporary Storage HP0/C0-74 of Radioactive Trash Radiation Area Posting 10 CFR 20.203(b)
High Radiation Area 10 CFR 20.203(c) and Posting and Control Technical Specification 6.13 Radioactive Material Posting, 10 CFR 20.203(f)
Labeling and Control No items of noncompliance were identified.
1127 065
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8.
Notifications and Reports The exposure records of six individuals who had terminated employment or completed their work assignment at the licensee's facility during 1978 were reviewed to determine compliance with the following requirements:
Area Requirements Exposure Termination Report 10 CFR 20.408 10 CFR 20.409 Requests for previous exposure 10 CFR 19.13 information The inspe car discussed the method the licensee uses to report an individual's radiation exposure upon termination at the facility.
The inspector stated that the information provided on previous termination reports did not indicate the required information.
Spec-ifically, during 1977, termination reports did not show specific periods of exposure for each termination report.
Licensee representatives stated that the method of furnishing termin-ation reports has been corrected to provide the necessary information and that termination reports issued in the second quarter of 1979 would reflect the new method.
The inspector stated that additional termination reports would be reviewed for that period.
9.
Surveys The inspector reviewed active Radiation Work Permits to determine compliance with the following requirements:
10 CFR 20.201(b), " Surveys"
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HP0/C0-1, " Area Survey for Radiation Dose Rate"
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HP0/C0-2, " Area Survey for Radioactive Surface Contamination"
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HP0/C0-3, " Area Survey - Airborne Radioactive Contamination" The following Radiation Work Permits were reviewed:
Radiation Work Permit No.
Description 2-03-0007 Change U-2 Suction and Discharge Filter 2-20-0044 Transport Radwaste (In-plant)
1127 066
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2-20-0005 Compact Radwaste 3-94-0096 Remove Fuel Storage Racks and Equipment No items of noncompliance were identified.
10.
Exposure Control The inspector reviewed the licensee's personnel monitoring program against the following requirements:
10 CFR 20.101, " Exposure of individuals to radiation in restricted
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areas"
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10 CFR 20.102, " Determination of accumulated dose"
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10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas"
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10 CFR 20.104, " Exposure of minors"
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10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal" Procedure HP0/CO-13, Revision 1, " Issuance of Personnel Dosimetric
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Devices" The inroector selected personnel exposure records of 13 individuals who wer i subject to exposure to radiation during the third and fourth calenda.' quarters of 1978.
The inspector confirmed that, in those cases whtre an individual's exposure exceeded 1.25 Rems per calendar quarter, the required occupational exposure history war complete on the Form NRC-4.
The inspector also reviesed the licensee's computer printout of updated personnel exposure.
The inspector neued that this method was equivalent to use of the Form NRC-5 in that the printout included the same information required by the Form NRC-5.
With regard to the yearly accumulated whole body exposure, the licensee representative informed the inspector that no individual received a dose in excess of five Rems for the 1978 calendar year while at the Peach Bottom site.
The inspector reviewed bioassay results (i.e., whole body counts) for approximately ten individuals who were subject to exposure to radio-active materials durinp the third and fourth calendar quarters of 1978.
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The bioassay results indicated that internal deposition was well below the maximum permissible body burden as well as the licensee's own investigation level, which is set at a lower value.
No items of noncompliance were identified.
a.
Personnel Monitoring Devices The licensee uses two types of personnel monitoring devices, Self-Reading Pocket 00simeters (SRD's) and Thermoluminescent Dosimeters (TLD's).
SRD's are normally used to provide an indication of external radiation exposure throughout a given day. The licensee uses two separate TLD badges.
One is processed by the licensee on site at the end of each day, the daily TLD value.
This infor-mation provides a day-by-day account of an individuals's personal exposure.
The other TLD badge is processed off site by a vendor at the end of each month.
The licensee normally regards the morf11y TLD as the official permanent record of personnel exposure.
The inspector asked the licensee representative at what point the licensee identifies and evaluates differences among the two types of TLD's.
The licensee representative stated that differences of 25 percent or greater between the monthly TLD results and the mon".h's accumulation of daily TLD results are identified by com-puter and printed out. The printout identifies the individual who received the exposure and lists the respective TLD results for that individual.
The inspector reviewed the monthly discrepancy printouts for the period from January through December 1978.
During the review, the inspector noted many instances, as shown in Table I, of significant discrepancies between the monthly and the accumulated daily TLD results.
The inspector asked the licensee representative whether the discrepancies listed in Table I had been evaluated.
The licensee representative indic, tad that they were not and that his evaluations of the discrepancy cases were done en somewhat of a sampling basis. Tnat is, a certain number of dosimetry discrep-ancies would be selected froni each printout, then evaluated to determine which TLD result would be applied as the individual's official permanent record of exposure.
The inspector analyzed the discrepancy results shown in Table I.
It was found that, in some instances, discrepancies as high as 500 mrem, as indicated by the accumulated daily TLD results, had been discounted in fa' or of the lower doses exhibited by the monthly 1127 068
TABLE I Dose Discrepancies * by Month 1978 Month's Accumulated Net Permanently Assigned Daily Doses Difference Percent bbnth Dose (mrem)
(mrem)
(in mrem)
Difference January 703 1,089 386
692 878 186
546 811 265
February 71 6 944 228
1,037 1,629 592
March
None Identified-------------------------
April 516 957 441
400 613 213
699 994 295
May 1,51 9 2,067 548
915 1,213 298
1,019 1,393 374
1,072 1,371 299
1,595 r,028 433
1,080 1,560 480
1,082 1,434 352
871 1,320 449
1,4 21 1,932 511
966 1,282 31 6
603 1,011 408
1,168 1,549 381
775 1,097 322
1,108 1,661 553
June
None Identified-------------------------
July 620 901 281
635 958 323
August
- -- - - --- -- --- -- -------- No n e I d e n ti f i e d - -- - - --- -- -- ---- - - -- -- - - -
September 893 1,218 325
1,647 2,127 480
820 1,063 243
1,499 1,907 408
1,364 1,824 460
- for doses in the range of m 400-2,000 mrem which were examined by the inspector 1i27 069
TABLE I Dose Discrepancies * by Month 1978 (Continued)
Month's Accumulated Net Pennanently Assigned Daily Doses Difference Percent Month Dose (mrem)
(mrem)
(in mrem)
Difference September 1,367 1,778 411
1,260 1,705 445
1,398 1,809 411
1,296 1,690 394
1,362 1,784 422
840 1,065 225
1,755 2,214 459
1,054 1,395 341
1,229 1,676 447
October 745 1,079 334
642 981 339
594 880 286
625 940 315
681 1,067 386
972 i,326 354
845 1,111 266
811 1,113 302
November
No n e I d e n ti f i ed ----------------------------
December
None Identified----------------------------
- for doses in the range of s 400-2,000 mrem which were examined by the inspector 1127 070
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TLD.
In all, the inspector noted 46 instances in which a significant accumulated daily TLD result was discarded without support of an evaluation.
Table II lists the range of these discrepancies in terms of percent.
Eleven instances involved differences (between the monthly and accumulated daily TLD's)
in the range of 21-30 percent; 17 instances involved differ-ences in the range of 31-40 percent; ten instances involved differences in the range of 41-50 percent; six instances involved differences in the range of 51-60 percent; and one instance occurred in each of the ranges of 61-70 and 81-90 percent.
These instances are well above the licensee's ten percent bias added to the daily TLD's (to account for fading).
The inspector noted that in instances of discrepancies where the licensee did conduct an evaluation, the difference between TLD results were relatively small; although other instances on the same printout involved relatively large differences.
For example, an instance involving one TLD result of zero mrem versus the other result of 59 mrem was selected for evaluation while other instances involving several hundred millirem differences (as high as 500) were not selected for evaluation.
The inspector noted that in making a determination of accumulated quarterly exposure, all dose information must be considered.
Higher doses indicated by the month's accumulation of daily TLD results could not be discarded in favor of lower results of the monthly TLD's unless a sound factual basis for the lower dose assignment could be developed.
10 CFR 20.201, " Surveys," requires in Section (b) that the licensee make surveys as may be necessary to comply with the regulations of Part 20.
The inspector identified the licensee's failure to evaluate the higher doses indicated by the accumulated daily TLD results when determining whether the exposure limits of 10 CFR 20.101(b), " Exposure of Individuals to Radiation in Restricted Areas," were excceded as noncompliance with 10 CFR 20.201(b).
(50-277/79-07-03; 50-278/79-06-03)
b.
Quality Control Program The licensee conducts spike tests of the monthly and daily TLD's as part of its personnel dosimetry quality control program.
On a quarterly basis, one of the licensee's vendors spikes, with a gamma source, the licensee's TLD's as well as the vendor's own TLD's (for intercomparison).
The results of those tests, in the 1127 071
TABLE II Range of Dose Discrepancies Range (%)
Number of Instances 0-10-0-11-20-0-21-30
31-40
41-50
51-60
61-70
71-80-0-81-90
91-100-0-
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range of 1,500 mR exposure, for the 1978 year are shown in Table III.
The inspector noted that for three of the four quarters, the daily TLD responded higher in relation to the monthly TLD.
The inspector observed the same relationship, in most instances, during his review of the dosimetry discrepancy printouts covering the 1978 year.
The inspector also noted that there were two cases where results varied from the usual range of test values.
In the first case results of the monthly TLD's were 17 percent lower than the average of the other test values (i.e., condensor-R meter, vendor TLD's, etc.).
In the second case, results from the first quarter monthly TLD's were higher in relation to the results from the daily TLD; this relationship does not conform to either the pattern of results from spike tests in the other three quarters, as shown in Table III, or the pattern of results reflected by the monthly dosimetry discrepancy printouts.
(Both patterns show that the daily TLD results normally tend to be consistently higher than the monthly TLD results.) The inspector noted that the licensee had not performed an evaluation of these cases to determine whether there was an anomoly involved or to identify a developing trend.
The inspector asked the licensee representative by what process the dosimetry spike test results were reviewed and evaluated.
The licensee representative stated that this is incorporated in Procedure HP0/CO-32, " Quality Control of Personnel Dosimetry,"
Revision 2, dated August 3, 1978.
The procedure specifies the frequency of evaluation and the method used for the acceptance criteria. The inspector noted the following through discussion with the dosimetry supervisor and a review of the procedure:
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The procedure specifies review and evaluation of results annually (although spike tests are conducted quarterly).
This means that a period of time on the order of eight months could elapse before spike test results were sub-jected to the evaluation outlined in the procedure.
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The dosimetry supervisor could not explain how the procedure was to be used with respect to how the calculation in the procedure was performed and with respect to what the accom-panying instructions in the procedure meant.
(The inspector subsequently reviewed the draft of the procedure and noted that words and phrases had been typed out of their intended sequence.
The result was that the instructions in that section were not understandable.)
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TABLE III Results* of Licensee's Quality Control
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Test for Calendar Year 1978 Showing Response to m 1,500 mR Exposure Permanent Calculated Condensor Vendor TLD Record +
Daily Quarter Exposure R-Meter Badge TLD Badge TLD Badge
1,670 1,700 1,780 1,996 1,725
1,512 1,460 1,580 1,468 1,669
1,480 1,390 1,400 1,1 59 1,584
1,490 1,300 1,360 1,384 1,508
- all values in mR.
+ monthly
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Less than one year had elapsed since the procedure was promulgated so no evaluation had been performed as of the inspection.
The inspector expressed concern regardir.g the licensee's cogni-zance and timeliness of review and evaluation of the quarterly test results.
The inspector noted timeliness of the evaluation is important in identifying anomolies or trends and subsequently initiating corrective action to compensate or prevent recurrence.
The inspector noted that the implementation of the procedure governing dosimetry test results will be examined during a sub-sequent inspection after the specified annual review falls due.
(50-277/79-07-04; 50-278/79-06-04)
c.
Detection Capabilities of Personnel Monitorina Devices The inspector asked the licensee representative whether the monthly (permanent record) TLD's were subjected to beta radiation spike testing as they are for gamma radiation.
The licensee repre-sentative replied that they did not conduct such tests for beta.
The inspector noted that the licensee must demonstrate the (TLD)
device's capability to respond to beta radiation such that results could be correlated to the beta dose received.
(Measurement of this type of radiation is necessary in order to determine com-pliance with occupational exposure limits to the skin of the whole body.)
The licensee representative acknowledged and plans to conduct tests which will expose the monthly (permanent record) TLD's to beta radiation at various energies and exposure levels.
In addition, the licensee agreed to provide the Region I office with twenty (20) TLD's so that an independent spike test could be conducted by the Comission.
The inspector noted that this matter is considered unresolved pending demonstration of the beta capability and review of test results.
(50-277/79-07-05; 50-278/79-06-05)
11.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items are discussed in Paragraphs 4, 5 and 10.
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12.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on February 16, 1979.
The inspec-tor summarized the purpose and scope of the inspection.
The licensee representatives made the following comments:
With regard to the exposure discrepancies, the licensee repre-
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sentatives acknowledged the inspector's findings and indicated that the matter would be reviewed (Parag-aph 10).
With regard to OSR Committee 1978 audits, licensee representatives
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stated that the OSR Committee audit procedure and audit reports covering parformance, training and qualifications would be forwarded to the Region I cffice (Paragraph 4).
With regard to requiring a specified time interval for calibration
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of portable radiation monitoring instruments as a procedural provision, this would be accomplished within 90 days.
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