IR 05000293/1985007

Insp Rept 50-293/85-07 on 850318-22.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Previous Findings,Bulletins & Circulars & High Reading TLDs Identified in Dec 1984 & Jan 1985

ML20129E109
Person / Time
Site:	Pilgrim
Issue date:	05/15/1985
From:	Carson B, Costello F, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129E089	List: IR 05000293/1985007 ML20129E086
References
50-293-85-07, 50-293-85-7, IEB-80-10, NUDOCS 8506060351
Download: ML20129E109 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

~ Report No. 50-293/85-07

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Docket'No. 50-293 License No. DPR-35 Priority -- Category C Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: March 18-22, 1985 Inspectors: k.L blM Sh'f183 R. L. Nimitz, Senior Radiation Specialist date R-L.Al M k F. M. Costello, Senior _ Radiation Specialist Sl8't IBS date V l hf& Scn S lli l2S

. a on Radiatio Specialist date Approved by: / b- ,, f.o ( ~

A 5 85 b h Y J . (a'0"Tak, Chief date BWR~RadLition Protection Section

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Inspection Summary: Inspection on Mar:h 18-22, 1985 (Report No. 50-293/84-44)

Area Inspected: Special announced inspection of the following: licensee action on previous findings; licensee action on bulletins and circulars; licensee action on high reading TLDs identified in December 1984 and January 1985. The inspection involved-64 inspector hours on site by three region based inspector Results: No violations or deviations were identified. Some problems were identified in the licensee's issuance, control, and Quality Assurance of personnel dosimeters, i

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DETAILS 1.0 Persons Contacted 1.1' Boston Edison Company

• D. Harrington, Senior Vice President-Nuclear A. L. Oxsen, Vice President-Nuclear Operations

• P. Mastrangelo, Chief Operating Engineer W. H. Deacon, Assistant to Senior Vice President

• E. Ziemianski, Nuclear Operations Support Manager

• A. R.-Trudeau, Chief ~ Radiological Engineer

• E. T. Graham, Compliance Group Leader J. Mattia, Audit Group Leader R. Smith, Chief Chemistry Engineer 1.2 Contractor _s D.'.R. Neely, Vice President-Hydro Nuclear

• G. H. Smith, Senior Radiological Engineer, Hydro Nuclear C. Yoder, Manager. Technology, Landauer In .3 NRC'

• J. R. Johnson, Senior Resident Inspector M. McBride, Resident Inspector

• denotes those-individuals attending the exit meeting on March 22, 1985

The inspector also contacted and interviewed other. personne .0 Purpose The purpose'of this special, announced radiological controls inspection was to examine the following program elements:

• Licensee Action on previous findings

• Licensee Action on Bulletins and Circulars

• Is:uance, Control,. Processing and Quality urance of personnel monitoring devices (i.e. thermoluminescer timeters [TLD]).

• Licensee Evaluation and Resolution of the fu. lowing; high reading TLDs:

• the TLDs worn by two individuals (A&B) in December 1984 (see Report No. 50-293/85-02).

• eight TLDs identified in January 1985'

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3.0 Licensee Action of Previous Findings 3.1. (Closed) Follow-up Item (50-293/80-05-16) Licensee to establish a program to rotate the sampling of charcoal beds on the licensee's safety related ventilation systems. The licensee established procedure 7.1.44, " Sampling of Charcoal Cells in Standby Gas Treatment and Control Room Environmental Filters Systems for Methyl Iodide Testing". The procedure provides ade-quate guidance for performing the sampling. Inspector review found that the procedure was being properly implemente .2 (Closed)' Follow-up Item (50-293/82-20-02) Licensee to establish a program to identify resin intrusion into ventilation duct work and initiate appropriate acti]n following its identification. The licensee established procedure TP 83-58, " Resin Inspection of H&V Duct Work". The procedure provides adequate guidance for performing the inspection. The licensee also established procedure TP 85-11, " Resin Removal from RBV". The procedure provides adequate guidance for resin remova . Inspector review found the procedures to be implemente However, the following matters were brought to the licensee's attentio * Procedure TP 83-58 data -sheets did not contain a s' pace for logging the date of inspection, consequently, the inspection history and time of procedure implementation was not clear based on data sheets reviewe Procedure TP 83-58 did not provide any guidance or steps to initiate a review to determine the source of resin intrusion into H&V duct work. No sign-offs for this matter were included in the procedure, consequently,

.the licensee's identification and removal program did not provide assurance that such action would be take The above two matters will be reviewed during a subsequent inspection (50-293/85-07-01).

3.3~ (Closed). Follow-up Item (50-293/83-02-01) NRC to perform a review of the licensee's post accident sampling facility. The licensee was notified that a special team inspection of the licensee's Post Accident Sampling capability would be performed in the near future. This item is closed

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for administrative purpose .4 (Closed) Follow-up Item (50-293/83-20-03) Licensee to revise the General Employee Training (GET) Program to include information to be provided to workers as to the types of radiation exposure reports that workers could request or expect to receiv Inspector review found that the licensee had modified the GET Program to provide for such information being provided to worker .5 (Closed) Violation (50-293/84-06-02) Licensee did not implement the requirements of 10 CFR 20.201. Inspector discussion with licensee representatives and review of documentation indicated the licensee implemented the corrective actions described in his May 16, 1984, letter to NRC Region _

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' 3.6 (Closed) Violation:(50-293/84-14-05) Licensee did not implement the requirements of 10 CFR:20.201._ Inspector discussions with licensee

' representatives and review of documentation indicated the licensee

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implemented the corrective action described in his August 30, 1984, letter to NRC. Region . 7 X (Cl osed) , Fol l ow-up1 Item . ( 50-293/84-14-06) Licensee toLimprov ecommunications between workers and: radiation protection personnel _at access' control-points. The licensee issued a memorandum to all

. appropriate radiation protection personnel regarding briefing of personnel performing radiation. work permit work.- Inspector review of training' documentation-indicated all appropriate personnel'were trained in the: memorandum. ' The -licensee has included the memorandum' in his radiation protection technician training progra .

13.8 (Closed)-Violatten (50-293/84-25-06) Licensee did not adhere to the requirements 'of TechnW1 Specification 6.8.~ The licensee implementation-of correction action .or this violation was reviewed in part during

' inspection 50-293/84-29. The inspector review of documentation and discussion with licensee personnel indicated the corrective action-specified'in the licensee's December 28, 1984 letter to NRC-Region _I was implemente .9 f(0 pen). Follow-up Item (50-293/83-27-01) Licensee to revise radiological

,. 1 occurrence report system as necessary to ensure that'necessary corrective actions for occurrences are identified and applied on a priority basi ~

L LInspector review of-the licensee's radiological occurrence program uindicated occurrences were being' categorized per type ofLoccurrence,

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summed per type of occurrence.and plotted in terms of occurrences per?

month. However, review of the corrective action section of a number of occurrence reports indicated no specific corrective action was documented to-identify the corrective actions-taken to prevent recurrenc '

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g . example, the occurrence. reports for a number of licensee' identified break-

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downs in high radiation area access controls (i.e. open doors) did not-M specify what;.if any, action was taken to prevent recurrence. The

inspector brought the matter'to the licensee's' attention and indicated

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this: matter remains open (50-293/85-07-02).

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.3.10.(Closed) Unresolved Item (50-293/85-02-02) NRC to review licensee's evaluation of a high reading TLD worn by an individual (Individual A) in December 1984. This matter is discussed _in section 5 of this report- .

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. 3.11 (Closed) Unresolved Item (50-293/85-02-03) NRC to review licensee's i evaluation of.a high' reading.TLD worn by-an individual (Individual ~B) in.

L . December >198 This. matter is discussed in section 5 of this report.

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3.12:(Closed) Unresolved : Item (50-293/85-02-04) NRC to review licensee

', s evaluation'of a high reading'TLD worn by an individual (Individual C) in

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. January 1985. This-matter is discussed-in section 6 of this report.

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3.13'(Closed) Follow-up Item (50-293/85-02-05) NRC to review the licensee's personnel dosimetry Quality Assurance Program. This matter is discussed in section 6 of this repor .0 Licensee Action or Bulletins and Circulators IE Bulletin 80-10 The inspector reviewed the licensee's implementation of the requirements of IE Bulletin 80-10, " Contamination of Nonradioactive System and Result-ing Potential for Unmonitored/ Uncontrolled Release to Environment".

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This bulletin required that the licensee perform the following:

• Review facility design and identify' nonradioactive systems which co'uld become contaminated through interfaces with-radioactive system * Establish a routine sampling and analyses or monitoring program for these systems in order to promptly identify any contamination events which could lead to unmonitored releases to the environmen * Restrict use of a nonradioactive system which becomes contaminated until the cause of the contamination is identified and corrected, and the system is decontaminated or if it is necessary to operate the system contaminated, perform an immediate 10 CFR 50.59 evaluatio (Note: This 10 CFR 50.59 review is to address the matters discussed in the bulletin.)

The evaluation of the licensee's performance was based on:

• Review of licensee response (dated July 11, 1980; BECO Ltr #80-141)

and supporting documentatio * Discussion with licensee chemistry personne Within the : cope of this review, the following matters requiring licensee attention were identified:

• The licensee's Chemical Engineer had not seen the documented system

. evaluation performed to identify contaminated systems which interface with noncontaminated system. Consequently it was not evident that the licensee had established all necessary sampling / monitoring programs to monitor noncontaminated systems which could lead to an unmonitored release. The licensee should review the system sampling program'to ensure all appropriate systems are sampled or monitored.

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• The licensee's evaluation did not clearly identify which systems could lead to an unmonitored/ uncontrolled release to the environmen The license should clearly identify such system *The licensee has not selected (a priori) a specific lower limit

of detection for radioactivity with which to:

• Define what is a radioactive / nonradioactive system; and

• develop sampling and analysis programs in. order to' assure that a certain minimum defined concentration is identifie (NOTE: The licensee's evaluation stated that fluid concentrations in excess of 10 CFR 20 Appendix B limits define a radioactive syste However, the licensee did not indicate whether these were 10 CFR 20 Appendix B Table 1 or 2 values and whether they were for identified or unidentified radionuclides.)

The licensee should clearly identify this/these concentration *The licensee has.not established a program such that in the event a nonradioactive system is contaminated:

• the system is not used until it is decontaminated, or

• if the system is to remain in operation, an immediate 10 CFR 50.59 review (addressing the matters discussed in IE Bulletin 80-10) is performe The above matters were discussed with licensee representatives during the inspection and during a management meeting at the NRC Region I Office on March 27, 1985. Licensee representatives indicated these matters would be reviewed and appropriate action taken. These matters are unresolved and will be reviewed during a subsequent inspection (50-293/85-07-03).

5.0 Licensee Evaluation and Resolution of High Reading TLDs 5.1 Background g-On December 14 and 22, 198 , the licensee identified two high reading personnel monitoring devices (thermoluminescent dosimeters [TLD]) worn by two individuals at the Pilgrim Station. On January 15-18, 1985, a special NRC inspection (50-293/85-02) was conducted to review the circum--

stances and licensee evaluation of the high reading TLDs. At the time of the inspection, several NRC concerns were raised relative to: 1) adequacy of personnel dose evaluation for individuals who wore-the high reading

dosimetry and; 2) adequacy 7f issuance, control and quality assurance of the personnel ~ monitoring devices worn. These matters were discussed in part during a licensee /NRC meeting held at the NRC Region I office on January 31, 1985.

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(NOTE: An indepth discussion of the two high reading TLDs is included'in Inspection-Report 50-293/85-02)

In January 1985, the licensee also identified eight high reading TLD The. licensee's evaluation of readings of these eight TLDs was also reviewed during.this inspectio .2 December,:1984 High Reading TLDs (Two TLDs)

The inspector reviewed the licensee's action on a number of_NRC identified concerns relative to the two high reading TLDs identified in December 1984. The evaluation of the licensee's actions on these concerns was based on:

• inspector review of documentation and

• discussions with licensee representatives The following-provides the concern and the licensee's action / resolution of=the concern:

Individuals A and B Concern 1 The licensee was unable to inform the inspector as to what these-individuals were doing while in the Reactor Building and not signed in on a radiation work permit or what maximum radiation field these individuals may have been i Licensee Action on Concern 1 The licensee performed a comprehensive review of the whereabouts of the individuals while they were onsite and wearing their respective high reading TLD. badges. The licenses was able to provide the-maximum dose rates the individuals could have been exposed to while on site. Considering the time the individuals were onsite and the maximum radiation ' fields the individuals could have been in, the inspector concluded that the individuals did not sustain the exposure indicated by the high reading TLD Individuals A and B Concern 2 The licensee was unable to show that the individuals had not received an unplanned exposure from radiography source use.

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Licensee Action on Concern 2

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licensee reviewed the' use of radiography sources.during the time

_ period when the individuals were on site and wearing their respective high reading TL , The : licensee was able to show that the workers did not receive unplanned exposures from radiography source us Individuals A and B

Concern 3

.The licensee was unable to show that the individuals' pocket dosimeters had not malfunctioned and indicated a lower exposure value than actually received by the TLD badge worn by the irdividual Licensee Action on Concern 3 The licensee performed an evaluation of his entire pocket dosimeter compliment and determined that the pocket dosimeters worn at the station ~have a high degree of reliability. The inspector reviewed this data and concluded that-the dosimeters worn do not have a sig-nificant failure rate. The inspector was' unable to identify any

. incidence of pocket dosimeter failure which resulted in a high read-

' ing TL Conclusion LBased on the above reviews and the independent inspector reviews performed during inspection 50-293/85-02, the following conclusions were identified:

• The individuals were not present in a radiation field of suf-ficient magnitude-for a sufficient period of time to have sus-tained the exposures' indicated on their high reading TLD *The inspector could not identify any deficiencies in the licensee's review of' infield activities. The activities of the individuals involved would not have resulted in an unplanned exposure of the individual (Note: The review of the issuance, control and Quality Assurance of personnel dosimetry is discussed in section 7 of the report. A review of these are's was performed to determine if the high readings of the TL0s were associated with problems

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in the area of. dosimetry issuance, control, and Quality Assurance.)

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6.0 High Reading TLDs Identified in January 1985 6.1 Background In January 1985, the licensee identified an individual (Individual C)

whose TLD badge appeared to have received an unexplained exposure of about 1.7 rem. . The exposure of the badge was unusual in that the whole body TLD chip (chip 2) indicated a whole body dose of 1.7 rem while another whole body TLD chip (chip 3), contained in the badge did not indicate'any sig-nificant exposure. The third chip (chip 3) of the licensee's badge is a

"QA chip" which is used to provide a limited backup verification of TLD chip 2's result The badge also contains another TLD chip (chip 1) wnich

'is used to monitor dose to the skin. The 3 chips are contained on a

" card" and are essentially inseparable from each othe Subsequent review and evaluation by the licensee identified an additional 7 badges with similar exposure discrepancies between chips 2 and The licensee initiated reviews to determine the apparent cause of the TLD chip exposure discrepancies. These reviews included:

adose evaluations for the individuals who wore the TLDs,

• examination of TLD testing records, and

• review of the history of the usage of the TLD badge Based on the review, the licensee concluded that the 8 individuals who wore the TLD badges in January 1985 had not received the exposure indicated by the badges. The licensee stated that the exposures resulted from undocumented testing of the badges and subsequent failures to read out the exposure of TLD chip 2. The third chip of the TLD badges had been read out by the licensee's vendo .

6.2 NRC Review The inspector reviewed the following matters to determine the circumstances surrounding the exposure of the eight TLD badges:

• 1icensee dose evaluation for the eight individuals

• read out history of the TLD badges

• issuance program for TLD badges

• control program for TLD badges

• Quality Assurance Program for TLD badges

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6.2.1 Badge History Review-- '

Within the scope of this review, the following matters were identified:

• The.8 TLD badges were last used in August 1984. The badges were-read out (chip 1, 2, and 3) in early September 1984. No unusual

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readings were identifie *The 8 badges, based on available data, were-not used in September, October or November of 1984. The badges were not in'any radiation fields whila in storag *0n December 13, 1984, the third chip of each of the eight badges were read out by the licensee's dosimetry vendor. (NOTE: 'The third chips when read indicated a maximum of about 1.8 rem. However, because'the badges had not been assigned to any individuals after their use in August 1984, the licensee's vendor did not report tSe-dose-to the licensee.)

• In January 1985, the licensee issued the eight TLD badges to eight individuals in January'198 (NOTE: The badges were issued with out having been sensitized and "zerced" before issuance.)

• The licensee initiated a review in January 1985 when Individual C's TLD badge (chip'2) indicated an unexplained dose of 1.7 rem. At that

. time the licensee requested a read out of chip'3 for this individ-ual's badge and a low exposure was identified (50 mrem). The vendor later provided the third chip reading obtained-in September 198 The review of that data indicated the third chip reading was compar-

.able to the reading of chip 2. This was also the srie situation for the other 7 high reading TLD .2.2 Conclusion The inspector review of the circumstances surrounding the 8 high reading TLD results in the following conclusions:

• The eight individuals were not in radiation fields of sufficient magnitude or time duration to have sustained the indicated exposure *The licensee did not have adequate procedures for issuance of TLD badges in that. badges with up to about 1.8 rem exposure were issued to personne The licensee indicated that such procedures would be establish by April 30, 198 *The licensee was using out of date procedures for processing TLD 'The licensee removed the out of date procedures and verified that all appropriate personnel were trained on the new procedures.

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• The licensee did not have. adequate procedures for control of persannel dosimetry card The licensee indicated such procedures would be established by

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April 310 , 198 *The licensee did not have_ adequate procedures for evaluation of high or unusual readings on _ chip 3 of his TLD badg (NOTE: Some discrepancies as high as 68 rem were identified.)

The licensee indicated such procedures would be established by April 30, 198 The licensee stated that he will evaluate personnel exposures for all personnel where third chip TLD reading indicates exposures in excess of regulatory limits. This will be completed by June 1, 198 *The licensee does not appear to have an adequate TLD badge control program in that site personnel dosimetry is readily accessible by'

other personne Thezlicensee' indicated this matter would be reviewed and appropriate action take The inspector indicated that the above matter requires ifcensee attention and would be reviewed during a subsequent inspection 50-293/85-07-0 '2.3 Licensee Comments

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Licensee _ representatives indicated that his radiological improvement program would address overall improvement of the Personnel Dosimetry Progra .0- Exit Interview The inspector meet with licensee representative (devoted in Section 1) at the conclusion of the inspection or March 22, 1985. The inspector summarized the purpose, scope and findings of the inspection. At no time during the inspection did the inspector provide written material to the licensee.

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