IR 05000293/1986009
| ML20198K933 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/22/1986 |
| From: | Pasciak W, Rabatin K, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198K915 | List: |
| References | |
| 50-293-86-09, 50-293-86-9, NUDOCS 8606040167 | |
| Download: ML20198K933 (8) | |
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U.S. NUCLEAR REC'JLATORY COMMISSION
REGION I
Report No. 50-293/86-09 j
Docket No. 50-293 _..
License No. DPR-35 Priority
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Category C
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Licensee:
Boston Edison Company l
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800 Boylston Street ;
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J Boston, Massachusetts 02199 l
Facility Name:
Pilgrim Nuclear Power Station, Unit 1 l
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t Inspection At:
Plymouth and Braintree, Massachusetts
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Inspection Conducted: April 28'- May 2, 1986 i
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Inspectors:
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RichardK.Struckzeyer,fadiationSpecialist date
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,AbWh5bd S.2/ k(
Karen L. Rabatin,,Radiqfion Specialist
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date Approved by: bdA3% /.( M[k f[sa /p6
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Walter J. PJ sciak, Chief, ERPS, EPRB
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Inspection Summary: Inspection on April 28 - May 2, 1986 f,ReportNo. 50-293/86-09)
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Areas Inspected:
Routine, unannounced inspection of the radiological i
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environmental monitoring program for operations including: management l
controls; the licensee's program for quality control of analytical
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measurements; implementation of the radiological environmental monitoring program; and a followup on the licensee's actions on previous inspection findings.
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Results: Within the areas inspected, no violations were found. However, there is a lack of quality control for the environmental TLD monitoring. program.
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8606040167 860523 PDR ADOCK 05000293 G
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e DETAILS 1.
Individuals Contacted C. Bowman, Senior Radiological Engineer
- J. Crowder, Senior Compliance Engineer
- B. Eldredge, Acting Chief Radiological Engineer
- E. Gordon, Acting ERHS Group Leader L. Kearney, Mechanical & Chemical Test Supervisor, GTD B. Lunn, Plant Engineer, Compliance Group C. Morrill, Grade 3 Engineer, GTD
- J. Seery, Acting Station Manager L. Simons, Senior Quality Assurance Engineer D. Stauber, Technician, GTD E. Ziemianski, Section Manager, Management Services
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- Denotes those present at exit meeting on May 2,1986.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (293/83-08-03): Adequacy of Environmental TLD Program. The licensee implemented one program improvement identified in Inspection ;;.' ort No. 83-08, viz. the use of a new calibrator.
However, other program iniprovements listed in the inspection report have not been implemented. This is further discussed in Paragraph 7.
(Closed) Violation (293/83-08-04):
Failure to submit the 1982 annual environmental operating report within 90 days of January 1,1983. The inspector reviewed the submittal dates for the 1983 and 1984 environmental reports, and determined that the Technical Specifications requirements were met for the 1984 report.
The 1983 report was dated April 1, 1984, but the transmittal letter was dated April 5, 1984.
The revised Technical Specifications now require submittal of this report prior to May 1 of each year.
(Closed) Inspector Followup Item (293/83-08-05): Action to correct erroneous data,in 1982 annual environmental operating report. The inspector reviewed corrected plots of the air particulate composite data. No anomalous data were observed.
Subsequent reports have not included the nuclide specific plots for which this problem was noted.
(Closed) Inspector Followup Item (293/83-08-06): Alignment of upper instrument boom on 160 foot met tower. All meteorological instrument booms were properly aligned at the time of this inspection.
3.
Management Controls The inspector reviewed the licensee's management controls for the
Environmental Radiation Monitoring Program (ERMP), including assignment
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of responsibility, program audits, and corrective actions for identified
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program inadequacies and problem areas in the program, a.
Assignment of Responsibility The ERMP is administered by a senior radiological engineer in the Environmental and Radiological Health and Safety (ERHS) Group.
The ERHS Group Leader reports through the Radiological Section Manager to the Manager of the Nuclear Operations Department.
Collection of environmental samples is performed by personnel in the Mechanical &
Chemical Test Group. The Supervisor of this group reports through the Head of the General Test Division to the Manager of the Engineering Planning & Research Department.
Environmental samples, except TLDs, are analyzed by the Yankee Atomic Environmental Laboratory, a division of Yankee Atomic Elect _ric Company. Oversite
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of the laboratory's activities is provided by a committee of representatives from the utilities that utilize its services.
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The BEC0 representative on this committee, known as the Laboratory Quality Control Audit Committee (LQCAC), is the ERHS senior radiological engineer in charge of the ERMP.
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Program Review and Audits l
The inspector reviewed the audits of the ERMP conducted by the BECO
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Quality Assurance Department (QAD) in 1983, 1984, and 1985.
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The 1983 and 1985 audits identified several deficiencies that were subsequently resolved to the satisfaction of QAD and were closed out.
The inspector al:o reviewed the LQCAC audits of the Yankee Atomic Environmental Laboratory (YAEL) conducted in July 1984
and August 1985.
The laboratory's corrective actions for identified 1984 audit findings were reviewed and closed out by the LQCAC in its May 1985 meeting.
The licensee stated that a meeting was held in April 1986 in which the 1985 audit findings were reviewed; however, the minutes of this meeting were not yet available.
Close-out of the 1985 audit findings will be reviewed in a subsequent inspection.
4.
Laboratory Quality Control
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On a quarterly basis, YAEL submits reports to the licensee covering its quality control program, which consists of both intralaboratory and interlaboratory QC samples. The interlaboratory program consists of participation in the USEPA Laboratory Intercomparison Program. The inspector reviewed selected records of interlaboratory QC data, and noted that for a relatively large number of EPA samples analyzed by YAEL, there was a lack of agreement; 1.e., the results obtained by YAEL were significantly different from the "known" values supplied by the EPA.
In each case where agreement was not obtained, YAEL provided a reasonable explanation of the reasons for the disagreement. The explanations
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frequently call into question the validity of the samples and/or analyses provided by the EPA. The inspector stated that, due to the apparent problems encountered by YAEL with many EPA samples the licensee should
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considee augmenting its interlaboratory QC program.
Such augmentation
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might consist of additional QC samples and/or analyses by another independent laboratory. A representative of the licensee stated that this would be raised with the LQCAC in order that the various licensees
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utilizing YAEL's services would have an opportunity to act together to improve the interlaboratory QC program.
The licensee representative further stated that if the members of the LQCAC were unable to come to an agreement on this issue, BEC0 would pursue it alone or with those licensees willing to participate. The licensee committed to initiating
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improvements in the interlaboratory quality control program
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by October 1, 1986.
The licensee stated that improvements would first be made to those sample media for which frequent discrepancies have been noted between YAEL and the EPA, and would subsequently be extended to cover all media. This will be reviewed in a future inspection (293/86-09-01).
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Implementation of the Environmental Radiation Monitoring Program i
The inspector reviewed the licensee's commitments pertaining to its operational radiological environmental monitoring program, by discussions with the licensee, by review of reports, and by direct observation. The inspector concluded that the program generally conforms to the licensee's
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Technical Specifications.
The inspector examined selected environmental monitoring stations i
including water sampling stations, air samplers for fodines and
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particulates, and TLDs for direct radiation measurement. All equipment at these stations was operational at the time of the inspection. The inspector visited the General Test Division TLD laboratory and air
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sampler calibration facility, and reviewed procedures for collection and
handling of environmental samples, in particular those for the TLDs.
The inspector reviewed Environmental Radiation Monitoring Program reports for 1983,1984, and 1985 (pre-submittal copy). These reports provided a comprehensive summary of the results of radiological environmental monitoring around the Pilgrim Nuclear Power Station, and met the Technical Specification reporting requirement (Section 6.9.C.2).
.The inspector also compared the actual locations of selected
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environmental monitoring stations against the locations stated in the
Technical Specifications and in the Offsite Dose Calculation Manual (ODCM). Generally, a TLD and an air sampler are co-located; i.e.,
both devices are found within a few feet of each other.
Each location is
designated by a one or two-letter code. The inspector noted that in the case of locations PB, ER, WS, PL, MP, and possibly others, the distances and/or directions (sectors) given in the Technical Specifications and in the ODCM for the TLDs do not agree with those for the air samplers. The
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licensee stated that the actual distance and direction for each sample
location will be determined and that appropriate corrections will be made
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to the Technical Specifications and ODCM.
This will be reviewed in a
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future inspection (293/86-09-02).
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6.
Meteorological Monitoring l
The inspector examined the licensee's meteorological monitoring system, j
including the primary and backup meteorological towers, the recorder
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charts in the equipment house at the backup tower, and the charts in the
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control room for the primary tower.
There are no strip charts for the t
l backup tower in the control room.
The equipment appeared to be operating properly, with the following exceptions: The chart recorder for the 33-foot level of the 220-foot
tower had been removed for repairs.
Normally, a computer print-out of t
meteorological parameters is available as a back-up to the recorders, but
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at the time of this inspection, the computer had been out of service for approximately four to five days. The licensee stated that if this
.t situation were encountered at the time of an accident, meteorological i
data could be obtained by 'two-way radio from the back-up (160-foot)
tower. While the loss of two sources of meteorological data in the control room is not an ideal situation, the availability of the.back-up
tower appears to compensate sufficiently. The inspector noted that the i
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licensee's Technical Specifications contain no requirements for
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meteorological monitoring or for calibration of the meteorological i
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equipment. However, the licensee does calibrate the equipment quarterly.
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7.
Environmental TLD Program
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The environmental TLD program was reviewed in depth in Inspection Report i
No. 50-293/83-08. As a result of that inspection, the licensee stated that a number of improvements would be made. Up to the time of that inspection, the licensee had been using a depleted uranium slab
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calibration source, A new Shepherd Cs-137 calibrator had been purchased,
but had not yet been put into service. The licensee had. stated that the following program improvements, as a minimum, would be implemented by the
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end of June,1983:
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Use of the new Shepherd Cs-137 Calibrator for TLD calibration l
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determine the calibration traceability of the timer which is
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incorporated in the new Shepherd calibrator;
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determine through the TLD reader manufacturer what is appropriate
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i for reader calibration procedures (such as comparison of temperature i
meter reading with actual temperature) and calibration frequency; P
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compose and implement a written procedure for qualification and
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requalification of TLD system operating technicians; and, implement a written TLD quality assurance program incorporating at
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least the following elements:
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analysis of dosimeters " spiked" with a known exposure, 11) pre-determined acceptance criteria, iii) a written QA program procedure.
Of all the above commitments, the only one implemented has been the use of the new Shepherd calibrator.
Regarding the analysis of " spiked" dosimeters, it was noted that the licensee participates in the International Environmental Dosimeter Intercomparison Projects, but has
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no in-house program for performing this or other types of quality control checks.
It was noted during this inspection that the licensee's results
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in the seventh (1984) Intercomparison were not in reasonable agreement
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with the known delivered doses; the licensee's values were about one-half
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to one-third the known values, as shown in the following table:
i Type of Delivered (Known)
Licensee's Exposure Exposure (mR)
Results (mR)
Laboratory (Co-60)
75.0 1 3.8 25.8 1 6.6 Laboratory (Cs-137)
79.9 1 4.0 34.1 1 7.9
Field 75.8 1 6.0 39.1 1 8.4 The 1984 Intercomparison is the only study completed since the licensee began using its new calibrator. The results of the eighth Intercomparison (held in late 1985 - early 1986) had not been transmitted to the
. participants at-the time of this inspection.
The inspector reviewed the studies performed by Teledyne Isotopes to demonstrate compliance with Regulatory Guide 4.13 and ANSI N545-1975.
(Compliance with this Regulatory Guide and ANSI Standard is not required by the PNPS Technical Specifications).
These studies, performed between February and July,1978, indicated that all of the Regulatory Guide 4.13 criteria were met except the ' criterion for energy dependence. Teledyne indicated that it hoped to resolve this problem by developing a new TLD badge case. However, the licensee t.tated that this issue was never resolved to its satisfaction. After the new calibrator was put into use, the licensee followed the recommendation of ANSI N545-1975 to re-do the studies, in order to ensure that the TLD system would continue to perform
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within the ANSI guidelines. The studies undertaken by the licensee were
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those for Uniformity and Reproducibili.ty.
The licensee designed several studies to test its TLDs for conformance to these criteria. The test for Uniformity indicated that this criterion was met.
In the Reproducibility test, however, the licensee was unable to achieve results within the limits specified by Regulatory Guide 4.13.-
The licensee stated that attempts were made to obtain assistance from Teledyne, but that the problems were not resolved. Tests were performed between June 1983 and November 1984. The licensee stated that due to the difficulty of achieving acceptable results with the Teledyne TLDs, it began to consider the possibility of switching to another system to be provided by the Yankee Atomic Environmental Laboratory (YAEL). Although a decision to change to this system was made in mid-1985, the lack of availability of proper equipment at YAEL has nessitated a delay until at least January of 1987 to begin using the new system.
With regard to the qualification /requalification program for TLD system operating technicians, the licensee stated that a lesson plan had been written to fulfill this need, but that it was never implemented because the individual who wrote it had been re-assigned. The inspector reviewed the lesson plan and stated that it appeared to be adequate, but of no value if not implemented.
Based on this review of the PNPS environmental TLD system, the inspector made the following observations:
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The magnitude of any exposure using the new Cs-137 calibrator depends on the accuracy of the unit's timer. The licensee stated that it has no record of a calibration for this timer.
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In order to assure the accuracy of the TLD reader, it must be calibrated and cleaned periodically. The senior radiological engineer in charge of the ERMP, as well as the personnel in GTD where the TLD reader is maintained, stated that no calibration or cleaning had been performed on the TLD reader.
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No quality control program exists for the environmental TLD system.
The results of the Seventh International Environmental Dosimeter
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l Intercomparison Program indicated a significant under-reporting of i
the doses delivered by the program's spor.sor.
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The licensee's attempts to meet the Regulatory Guide 4.13 criteria for reproducibility were unsuccessful.
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A program for qualification /requalification of environmental TLD system operating technicians has not been implemented.
The inspector stated that in view of these apparent program deficiencies, the validity of environmental TLD data could not be assured. The licensee stated that studies would be initiated to attempt to determine the extent of the system's deviation from accurate performance, and to apply
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correction factors, if possible, to the data obtained in the last several years. The licensee stated that these studies would be completed by August 1,1986, and that if necessary, corrected results would be issued.
The inspecter stated that the results of these studies would be reviewed upon their completion (293/86-09-03). Also, the status of the environmental TLD program would be re-evaluated at that time (293/86-09-04).
In addition, the adequacy of any new environmental TLD system will be reviewed at such time as one is put into service.
8.
Exit Interview The inspector met with the licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on May 2, 1986. During this meeting the purpose and scope of the inspection were summarized and the inspection findings were discussed. At no time during this inspection was written material provided to the licensee by the inspector.