IR 05000289/1982005
| ML20053A631 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 05/07/1982 |
| From: | Fasano A, Moslak T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053A621 | List: |
| References | |
| 50-289-82-05, 50-289-82-5, NUDOCS 8205270033 | |
| Download: ML20053A631 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION j
50289-790328
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Region I
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f Report No. 50-289/82-05 Docket No. 50-289 License No. DPR-50 Priority
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Category C
f Licensee:
GPU Nuclear Corporation y
P.O. Box 480
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Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection at: Middletown, Pennsylvania i
l Inspectic ted: Man h 30, J98 h April 23, 1982
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Inspector:
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T. 'MosT5k? Radiatton SpeciaTist da'te signed'
Reviewed by:
M IM S/7/f2.
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M. Shanbak'y, Senio~r Padiation Specialist d&te ' signed
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Approved by:
N O'J d D S- ~
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A. Fashrio, Chief, Three Mile Island Section date signed
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l Projects Branch No. 2 I
Inspection Summary:
Inspection on March 30, 1982 - April 23, 1982 (Report No. 50-289/82-05)
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Areas Inspected: Routine, unannounced safety inspection by a site inspector of
licensee action on previous inspection findings in the areas of radiological instrument calibration, thermoluminescent dosimetry (TLD) performance, exposure control, radioactive waste processing and storage, environmental sampling, and
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procedures. The inspection involved 68 inspector-hours.
Results: Of 27 items reviewed, 22 are considered closed and 5 remain open. No
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violations were identified.
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Details 1.
Persons Contacted GPU Nuclear Corporation
- G. Baker, Padiological Programs Manager
- J. Colitz, Manager, Plant Engineering E. Fuhrer, Radwaste Operations Manager
- G. Kuehn, Deputy Manager, Radiological Controls
- W.Miller, Licensing EngineerG. Lawrence, Foreman, Preventive Maintenance
- W. Potts, Manager, Radiological Controls H. Shipman, Senior Operations Engineer
- C, Smyth, Licensing Supervisor P. Snyder, Preventive Maintenance Manager D. Tuttle, Radiological Engineering Manager P. Velez, Radiological Controls Field Operations Manager
- T. Walsh, Meteorologist S. Williams, Radiological Engineer
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (289/78-08-01):
dosimetry (TLD) performance evaluation.
Environmental thermoluminescent following documents.
The inspector reviewed the i
Met-Ed 1977 Radiological Environmental Monitoring Report prepared by
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Teledyne Isotopes GPU Nuclear 1982 Radiological Environmental Report
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Teledyne Isotopes TLD Performance Evaluation for conformance with
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Regulatory Guide 4.13 and ANSI N545-1975 The inspector reviewed the licensee's analytical records subsequent to the 1977 data in question and discussed this item with the licensee.
higher (by approximately 60%) TLD results for the fourth quarter of 1977 The than for the preceding three quarters of 1977 are attributed to an
atmospheric nuclear weapon test by the Peoples' Republic of China that occurred in September 1977.
licensee's replecing the TLD services of the Radiation ManagementSinc performed by TI to demonstrate that their TLD performanc mendations of Regulatory Guide 4.13 and ANSI N545-1975.
reviewed this evaluation and had no further questions in this area.The inspector (Closed) Violation (289/78-08-02 :
airborne particulate samples as r)equired. Failure to collect airborne iodine and During an inspection in environmental airborneApril 1978, the inspector determined six exceptions when w particulate and airborne iodine samples were not
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43-collected and analyzed as required. The licensee response to the NRC had detailed several correctiv2 actions including purchase of additional sampling equipment, increased surveillance of samplers, and implementation of an air sampler preventive maintenance program. Based upon the review of the licensee's environmental air sampling program conducted in combined inspections 50-289/81-09 and 50-320/81-09, and this inspection, this item is considered closed.
(Details are in inspector followup items 289/81-09-03; 320/81-09-02, which are discussed in paragraph 2 of this inspection report).
(Closed) Unresolved Item (289/78-08-05 and 320/78-16-04):
Cleaning, inspection, and maintenance of settling basins. The inspector reviewed the following documents.
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Operations Surveillance Procedure (OPS)-S193, General TMI-l Inspection of Remote Areas by Operations Engineers, approved December 16, 1981
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OPS-544, Southeast Dike and Swale Inspection, approved September 2, 1976
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Special Operating Procedure 79-45, Unit 1 Natural Draft Cooling Tower (NDCT) Drain and Flush, approved July 20, 1979
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Letter from Chief, Operations Section, Pennsylvania Department of Environmental Resources to Operations Engineer Nuclear, Metropolitan Edison Company, dated April 9, 1981 The inspector determined through discussions with the licensee, observations of the yard drains, and review of the licensee's documentation that a program had been established for the inspection, maintenance, and cleaning of the settling basins. The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/78-18-04): Review radiation levels on containment dome and verify that surveys are maoe before personnel perform tendon surveillance on dome during reactor operations. Through discussions with the licensee, review of applicable procedures, and examination of the licensee's corrective actions, the inspector determined that the licensee had taken appropriate action in terms of modifying Radiological Control Procedure (RCP) 1602, Radiation Dose Rate Surveys, effective April 22, 1982.
This procedure revision required gamma and neutron dose rate surveys to be performed on the outside dome of the reactor building prior to personnel ascending to the dome. A sign has also been placed at the ladder base requiring personr.el to contact the Radiological Controls Department prior to ascending to the dome.
The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/79-CI-21): Licensee action on IE Circular 79-21, Prevention of Unplanned Releases of Radioactivity.
Through discussions with licensee representatives and review of documentation, the inspector verified that the licensee performed reviews of procedures and reviewed "as-built" systems as recommended in IE Circular 79-21.
The inspector reviewed contamination surveys of the Borated Water Storage Tank area and determined that the leakage referenced
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-4-in IE Inspection Report 50-289/80-29 was a minor leakage originating from the chemicals addition system which contains no contaminated water.
In addition, the inspector reviewed RCP 1776, Sampling of Unmonitored Potential Radioactive Release Paths and Station Health Physics Procedure 1699B, Administrative Controls for Sump Pumping. These procedures address sampling requirements and controls to ensure that no radioactivity is discharged to the environment via normally uncontaminated liquid pathways
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such as the Turbine Building Sump and the Auxiliary Boiler Blowdown Sump.
The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/79-IR-02): Unlocked entry to high radiation area.
The inspector reviewed the licensee's procedures which implemented the access controls to high radiation areas during accident
conditions.
Revised Emergency Plan Implementing Procedures (EPIP) 1004.9 and 1004.18 describe specific measures to control access and incorporates the guidelines of the National Council on Radiation Protection (NCRP No.
39) and 10 CFR 20 to control personnel exposures during emergencies.
Based on this review and discussions with licensee representatives, the inspector determined that corrective actions were completed for this item.
(Closed) Inspector Followup Item (289/79-IR-03):
Inadequate personnel monitoring in high radiation areas. The licensee provided additional information regarding improvements in the area of personnel monitoring.
Emergency monitoring equipment, dedicated for use in emergency situations, has been placed at strategic locations, such as:
the Health Physics Laboratory, Control Room, and Security Processing Center. This equipment is maintained and inspected in accordance with Administrative Procedure (AP) 1053, Emergency Equipment Readiness Checklist, Revision 2, effective November 23, 1981. AP 1053 addresses the specific types, quantities, and frequency of inspection of equipment which will be maintained for
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emergency use.
In the event of an emergency, RCP-1602, 1605, and 1609 will be used in conjunction with the appropriate Emergency Plan Implementing Procedures to conduct dose rate surveys, airborne sampling,
and surface contamination surveys.
Based on examination of the licensee's actions, discussions with licensee representatives and selective inventory checks of emergency equipment, the inspector determined that corrective actions were completed for this item.
The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/79-IR-05; 289/81-20-10): Auxiliary operator's whole body dose exceeded quarterly limit.
The licensee provided additional information regarding corrective action to maintain control over whole body doses during accident conditions.
Emergency Plan Implementing Procedure 1004.9, In-Plant Radiological Controls During Emergencies, Revision 1, effective June 12, 1981, addresses dosimetry, j
instrumentation, briefing / debriefing, protective clothing, and bioassay requirements for emergency teams.
In addition, checklists are provided to
ensure that appropriate instrumentation, protective clothing, respiratory protection devices, and personnel monitoring equipment are used for in-plant surveys.
Based on this review and discussions with licensee representatives, the inspector determined that corrective action was completed for this item.
The inspector had no further questions in this area.
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-5-(Closed) Inspector Followup Item (289/79-IR-06):
Nuclear engineer's whole body dose exceeded quarterly limit. The licensee provided additional information regarding corrective actions taken for this item. The Emergency Plan has been modified to include exposure guidelines in emergency situations.
Emergency Plan Implementing Procedures include the guidelines of the National Council on Radiation Protection (NCRP No. 39)
and the requirements of 10 CFR 20 to the specific phases and situations that may be encountered in an emergency.
The Radiological Safety Training Program for all personnel employed at TMI-l has been revised and is in progress.
Emergency Team training is given to essential personnel in search and rescue, emergency repair, and radiological controls.
Radiological Controls Procedure 1690 and Administrative Procedure 1052, which define the training program requirements, have been implemented.
Retraining is being conducted on an annual basis.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and examination of selected procedure and documents, the inspector determined that corrective actions were completed for this item.
The inspector had no further questions in this area.
(Closed) Inspector Followup Items (289/79-IR-07 and 289/79-IR-08):
Chemistry foreman's whole body dose exceeded quarterly limit; and Chemistry foreman's and radiation protection foreman's hands and forearms dose exceeded quarterly limit. The l' ensee provided information regarding corrective actions to control and monitor doses received by individuals during emergencies. The ALARA (As low As Is Reasonably Achievable) program has been implemented.
Radiological (ALARA) engineers reviewed work requests meeting the criteria established by the Radiological Controls Department for tasks in areas or on systems having a potential for personnel exposure to radiation. ALARA engineers are on call on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis to perform these reviews.
The purpose of these reviews is to assess the radiological conditions and to determine the most effective manner to perform the task while maintaining
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personnel exposures as low as is reasonably achievable. Techniques considered in reducing exposures including flushing operations, shielding, special tooling, and the the use of containment systems are addressed in procedures.
In addition to operational techniques, the need for mock-up training and/or worker briefings prior to the performance of the task are considered.
Mock-up training, worker briefings and operational techniques are used on major evolutions conducted at Tf1I-1.
RCP 1651, Revision 1, ALARA, was issued February 3,1981.
The specific method for post-accident sampling is described in Energency Plan Implementing Procedure 1004.15 which became effective December 23, 1980.
Based on examination of the licensee's stated corrective actions, discussions with licensee representatives, and examination of selective radiological procedures, the inspector determined that corrective actions
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were completed for these items.
The inspector had no further questions in this area.
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-6-(Closed) Inspector Followup Item (289/79-IR-20):
Failure to perform annual calibration of environmental samplers.
The inspector determined through examination of surveillance procedure 1302-5.24, Revision 5, effective March 26, 1982, discussions with licensee representatives, and review of completed calibration records for the environmental samplers, that the licensee had completed corrective action for this item. The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/80-BU-03):
Loss of charcoal from standard type II, 2 inch, tray adsorber cells. The inspector examined licensee inspection records and interviewed licensee representatives to verify that actions to prevent the loss of charcoal from adsorber cells had been taken. The inspector verified that the licensee had completed a visual inspection of the filter housings and adsorber cells as described in Section 5 of ANSI N510-1975 as required by the bulletin.
No anomalies were found for rivet spacing, cell integrity, cell and cell housing deformation, and screens / casing separation. The results of the licensee's inspection were sent to the Director, Region I, Office of Inspection and Enforcement on March 25, 1980. The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/80-22-36):
Provisions for resolving time corrections in Geiger-Mueller (GM) detector counting procedures and determination of gross beta efficiency using appropriate backscatter corrections. The inspector reviewed RCP 1712, Operations, Calibration, Maintenance, and Repair of the Ludlum Portable Scaler, Model 2000,
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Revision 4, effective April 6,1981, and RCP 1747.1, Operation of the Ortec Scaler, Model 775, Revision 2, April 9,1981. These revised procedures incorporated resolving time corrections for the detectors.
The inspector also reviewed an evaluation performed by the licensee for determining counting efficiencies for radiological control instru-mentation. This evaluation documents the series of tests performed to determine appropriate efficiencies for counting equipment used by Radiological Controls personnel in determining airborne and surface contamination levels.
By a joint merorandum dated April 2, 1982, from the Manager, Radiological Controls TMI-1, and the (Acting) Radiological Controls Director TMI-2; the TMI-l and TMI-2 Radiological Controls Department Managers, directed to initiate applicable procedure changes to implement the recommended instrument efficiencies as determined in the evaluation.
In addition, the Radiological Training Manager has been requested to incorporate these changes into the Radiological Controls Technician Training Program.
The licensee's evaluation addressed NRC concerns related to a previous licensee evaluation of counter efficiency which did not use an efficiency value with a backscatter comparable to the value exhibited during actual air sample counting with filter paper.
This current licensee evaluation provides the method used in preparing representative calibration sources and the results of efficiency determinations for GM and gas flow proportional counters.
In determining the efficiency factors, the calibration source will have the same physical configuration and isotopic composition as the samples to be measured.
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Based on examination of the instrument efficiency evaluation, the licensee's stated corrective actions, selected radiological procedures, and discussions with licensee representatives, the inspector determined that corrective actions were completed for this item. The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/80-22-38): Review installation of Hittman Solidification System and the associated Appendix I Technical Specification process control program.
During the special NRC evaluation of the TMI-l Health Physics Program (Inspection Report 50-289/80-22),the auditors were unable to complete the review of this area because the licensee was in the process of completing commitments to the NRC with regards to the Process Control Program associated with this system.
The Hittman Solidification System was subsequently reviewed by the NRC in December 1981. The findings are addressed in NRC Region I Inspection Report 50-289/81-34.
(0 pen) Inspector Followup Item (289/80-22-39):
Review expansion of the TMI-l waste storage facility and associated operating procedures.
The inspector was unable to complete the review of this area because the Interim Solid Waste Storage Facility was not ready for use. Although construction has been completed, floor sealing must be refinished by the licensee's contractor before the facility is acceptable for use.
In addition, the associated operating procedures were not established and approved.
This item remains open and will be reviewed during a subsequent NRC inspection.
(Closed) Inspector Followup Item (289/80-22-47): That portion of gaseous and liquid effluent monitoring system calibration program. The inspector reviewed the licensee's surveillance procedures regarding the TMI-l Radiation Monitoring System (RMS) and discussed the RMS calibration program with licensee representatives.
The current calibration program consists of daily and weekly source checks, monthly electronics functional checks, quarterly calibrations, and four year linearity checks. This program is scheduled and controlled using a computer-based Technical
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Specification Surveillance System. Calibrations and linearity checks are also reperformed as appropriate following significant maintenance, including detector replacement.
The calibrations are performed on gaseous and liquid channels using single button sources traceable to calibrations at the vendors' plant. The area gamma monitors are quarterly calibrated at three points using a calibration kit with similar traceability. The liquid and atmospheric channel linearity checks are performed using three traceable button sources of the same isotope at different activities. These checks verify proper response over several decades.
Surveillance results of all calibrations and linearity checks performed initially in 1974 and subsequently repeated in 1978 are maintained on file. The most recent (1978) set of linearity checks has shown that readings correlate within the acceptance criteria for the established surveillance procedure. As per the licensee's surveillance requirement, linearity checks are schiduled to be performed on all liquid and gaseous effluent monitors during the last quarter of 1982.
Based on an examination of licensee
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-8-procedures and discussions with licensee representatives, the inspector determined that the licensee's calibration methods are appropriate. The inspector had no further questions in this area.
(Closed) Inspector Followup Item (289/80-22-48h Calibration factors relating radioactive effluent concentrations to actual count rate should be established and posted on process radiation monitor readouts in the control room. The inspector examined the control room process radiation monitor readouts for the gaseous and liquid effluent monitors, reviewed operating and surveillance procedures related to the calibration and testing of the effluent monitors, and discussed these methods of calibration and testing with licensee representatives.
For gaseous monitors, the sensitivities in terms of CPM /uCi/cc have been established and posted for all gaseous channels and for the particulate channel of process monitor RMA-2 (only detector using moving filter paper).
All other atmospheric particulate and iodine monitors are equipped with fixed filter detectors. The sensitivities of these monitors are estab-lished and posted in terms of CPM / min /uCi/cc.
Fixed filter detectors are designed to measure buildup of activity on a filter.
The concentration of iodine and particulate activity in the media being sampled is directly related to the increase in activity being deposited on the filter.
Therefore, airborne iodine and particulate activity is measured by the rate of increase in the count rate monitored by the detector. Step increases in activity in the media being sampled would be measured since the step increase in the activity on the filter would result in a ramp increase in the monitor readout, the slope of which would indicate amount of activity. Quarterly calibration of the monitors reestablishes the sensitivities of the monitors as posted.
For all liquid effluent monitors the sensitivities are established and posted in units of CPM /uCi/cc.
Based on this examination of the licensee's posting of sensitivities on control room readout modules, review of licensee surveillance procedures, and discussions with licensee representatives, the inspector determined that adequate corrective actions were completed for this item.
(0 pen) Inspector Followup Item (289/80-22-49):
Periodic calibration of area gamma radiation monitors in excess of current 5 R/hr upper calibration point. The inspector's review of licensee's records indicates that the use of calibration sources of higher activity is being evaluated.
A vendor has been contracted to furnish field calibration kits with higher activity. The licensee stated that presently the vendor has submitted its calibration source design material to the NRC for licensing. Upon approval of this unit by the NRC and the vendor will submit price and delivery date to GPU Nuclear Corporation. The inspector stated that this item will remain open until the licensee established a periodic cali-bration program for the area gamma radiation monitors in excess of the current upper calibration point (5 R/hr) using either electronic calibration or radioactive sources.
(Closed) Violation (289/80-22-53): Quality Assurance criteria require-ments for shipping packages for radioactive material were not met. The inspector determined through procedural review, inspections of completed
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_9 radioactive waste shipment records, and discussions with licensee representatives that applicable operating procedures had been revised to include witnessing mandatory quality assurance inspection hold points during shipping cask loading and closing operations; and to include listing the serial number and calibration due date for the torque wrench used for cask closure. The inspector had no further questions in this area.
(0 pen) Inspector Followup Item (289/81-CI-09):
Licensee action on IE Circular 81-09, Containment effluents that bypass radioactivity monitor.
The inspector determined through discussions with licensee representatives and examination of licensee records that an ongoing review regarding IE Circular 81-09 has been assigned to the TMI-l Manager, Plant Engineering.
The targeted completion date is October 1982.
This item remains open pending completion of the engineering review, and will be examined in a subsequent NRC inspection.
(0 pen) Inspector Followup Item (289/81-07-01): Assessment of proposed personnel neutron dosimetry during power ascension testing. Based upon the inspector's review during inspection 50-289/81-07 and this inspection, this item is considered open pending the assessment of the accuracy of the i
licensee's proposed personnel neutron dosimetry methods during power ascension.
(Closed) Violation (289/81-09-02; 289/78-08-04; 320/81-09-02):
Failure to achieve required lower limit of detectability (LLD) for Sr-89 in drinking water. The inspector determined through discussions with the licensee, review of the analytical records, and the review of the licensee's documentation of the followup action, that the licensee has met the analytical sensitivity requirements for Sr-89 in this medium. The inspector had no further questions.
(Closed) Inspector Followup Item (289/81-09-03; 320/81-09-02):
Evaluation of air sampler equipment performance. The licensee had increased surveillance of the equipment and had instituted a preventive maintenance program. An environmental scientist has been assigned the responsibility of the staff project coordinator who would oversee the weekly inspections of the air samplers, followup on work order completion, and monitor the overall reliability of the air sampling equipment. The inspector reviewed the licensee's records and discussed the status of the preventive maintenance program with the licensee. The licensee is replacing the present environ 0 ental samplers with 12 pressure and temperature
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compensated air samplers. Based on an examination of the licensee's
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stated corrective actions, discussions with licensee representatives, and examination of selected records, the inspector determined that adequate corrective actions were completed for this item.
(0 pen) Unresolved Item (289/81-09-01): Air sampler volume corrections for vacuum. During inspection 50-289/81-09, the inspector noted that vacuum gauges were not installed as part of the air sampling apparatus. The inspector discussed with the licensee the need for accounting for pressure-drop effects across the sampling filters on sample volume measurements and subsequent calculation of airborne radioactivity levels.
Because the volume meter is operating at reduced pressure relative to
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Subsequent to inspection 50-289/81-09, the licensee attempted to evaluate the effects of reduced pressure on air sampler gas volume meter readings.
The licensee was unable to perform an accurate in-place evaluation of air sampler performance because the sampling equipment could not be adapted to installing vacuum gauges.
However, the licensee is purchasing 12 pressure and temperature compensated air samplers (Purchase Order 9420-0) that will enable an accurate evaluation of the effects of filter dust loading and atmospheric temperature / pressure variations on total sample volume.
This item remains open pending this determination by the licensee of the magnitude of compensation for vacuum effects on air sampling.
3.
Inspector Followup Items Inspector followup items are inspector concerns or perceived weaknesses in the licensee's conduct cf operation (hardware or programmatic) that could lead to a violation if left uncorrected.
Inspection followup items are addressed in paragraph 2.
4.
Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether they are a violation, a deviation, or acceptable.
Unresolved items discussed during this inspection are discussed in paragraph 2.
5.
Exit Interview On April 23, 1982, a meeting was held with licensee representatives (denoted in paragraph 1) to discuss the inspection scope and findings. At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings.
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