IR 05000293/1991003
| ML20029C271 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/07/1991 |
| From: | Mann D, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029C265 | List: |
| References | |
| 50-293-91-03, 50-293-91-3, NUDOCS 9103270090 | |
| Download: ML20029C271 (7) | |
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NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-293/91-03 Docket No.
50-293 License No.
QPR-63 Licensee: Boston Edison Comoany RFD #1 Rocky Hill Road Plymouth. Massachusetts 02360 Facility Pame: Pilarim Nuclear Power Station Inspection At: Plymouth. Massachusetta Inspection Conducted: Eebruary 25 - March 1, 1991 [[u,. MM /d/O Incpector: D.
Msnn, Radiation Specialist date Facilities Radiation Protection Section Approved by: / 'h(O S - 7-9 / C 4 n."Pasdtth, Chief, Facilities date Radiation Protection Section, DRSS Insoection Summary: Inspection on February 25 - March 1, 1991 (Report No. 50-293/91-03).
Areas Insoected: A routine, unannounced inspection of the radiological controls program on site was performed.
Areas inspected included; a review of the calibration programs for the whole body counter, pocket ion chambers, digital alarming dosimeters, and survey instrumentation, as well as a review of the procedures associated with these areas.
An internal audits and surveillances review, and a facility tour was conducted.
Results: Within the scope of this inspection, no violations were identified.
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. DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel
- R.
Anderson, Vice President - Nuclear Operations
- R.
Cannon, Compliance Division Acting Manager M. Christopher, Radiation Protection Supervisor - Operations K. Conniston, Radiation Protection Technician
- N. DiMascio, Radiation Protection Section Manager P.
Droof, Sr. Supervisor Radiological Engineering - Dosimetry
- C. Gannon, RC&CP Department Deputy Manager
- E.
Kraft, Plant Manager
- S.
Landahl, Radiological Technical Support Division Manager
- W.
Mauro, Radiological Operations Division Manager
- J..McClellan, Sr. Quality Assurance Engineer
=B.
Mcdonald, Radiological Operations Support Division Manager
- T. McElhinney, Sr. Compliance Engineer
- V.
Oheim, Regulatory Affairs Manager B. Olson, Radiation Protection Supervisor - Calibrations D.
Perry, hadiation Protection Supervisor - Operations
- L. Schmeling, RC&CP Department Manager
- L. Whittenberger, RC&CP Department Deputy Manager J. Wudyka, Supervisor - Respiratory Protection
. 1.2 NRC Personnel A. Corne, Resident Inspector
- J.
MacDonald,-Senior Resident Inspector-
- W.
Olsen, Resident Inspector
- Denotes thse present at the exit interview on March 1, 1991._'Other licensee employees were contacted and interviewed during this inspection.
t l2. 0 Orcanization and Staffina The inspector reviewed the recent licensee re-organization.
involving both the Radiological Section and.the Radwaste &' Chemistry Section.
In the previous organization, the Radiological Section Manager and the Radwaste & Chemistry Section Manager reported to different department managers.
The re-organization created the Radiological Control and Chemical Processes (RC&CP) Department.
The RC&CP department encompasses both the Radiological and-the Radwaste &- .
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Chemistry Sections.
_This structure places those su.tions dealing with_ radiological controls under_a manager whose primary focus is radiological controls.- The inspector felt , that this was a good licensee initiative.
In addition, the ALARA section no longer reports directly to the outage and planning organization and instead reports to the Radiological.Section Manager.
The inspector noted that .the former organization, with the ALARA section repoi-ting ' , directly to the outage and planning organization, was credited as a program strength in the Maintenance Team inspection report numbered 90-80.
. 3.0 Internal ExDosure Controls The inspector _ reviewed the operation and calibration of the Whole Body Counter (WBC).
The WBC consists of a single germanium detector-in the Masse Chair configuration.
The-system is calibrated on a yearly frequency and undergoes a quarterly quality. control (QC) test.
Yankee Atomic Electric-Laboratory (YALL) provides the samples and performs the quarterly QC tests.
The tests consist of several blind = spiked samples usingDa humanoid phantom with internally dispersed radioactive material.
The inspector reviewed records of-recent quarterly QC tests and noted that-the WBC obtained acceptable results.
Daily 1QC counts ~are also taken for the WBC.
Five measuroments are taken immediately'following calibration of .the'WBC, to establish a mean, standard deviation, and a-- ' threc standard deviation value.
The= inspector noted-that the computer algorithm uses these_ values to= establish control charts.
. The-WBC isicalibrated using a mEufsource that is uniformly-distributed-throughout:the appropriate phantom organs.
The ~ ,. L inspectcr observed that this practiceLallows a photon energy ( gap of >200 kev across the1440-780 kev-energy range.
This practices isinot consistent with-'American National-Standards Institute (ANSI) N42.14-1978, " Calibration-and Usage of' Germanium Detectors for Measurement of~ Gamma-Ray Emission of.
i Radionuclides",-whichfrecommends,f n section-6.5, that calibrations be made at least every 0.1-MeV from_0.06 to ' l O.30-MeV, about-every 0.2-MeV from 0.3.MeV to 1.4 MeV, and-at least at_one energy between 1.4 MeV and 2 MeV.
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standard also recommends that a calibration with the same radionuclides that are to be measured should be made whenever possible.
The inspector observed that "2Eu is not a radionuclide that was likely to be measured at the facility.. These observations were discussed with the responsible supervisor.
The supervisor agreed that the program would be easily improved by including "Co and "7Cs as; calibration sources.
The inspector concluded that, with the inclusion of these tv radionuclides, the licensee program would meet the intent of the ANSI standard regarding . " this issue.
ANSI N343-1978, " Internal Dosimetry for Mixed Fission and Activation Products", section 15.1 states in part; that the radiation background of the system should not be significantly influenced by variations in ambient fields.
The inspector observed that background levels at the WBC facility range from approximately 100 to 450 counts per second (cps).
The inspector expressed some concern that this fluctuation was inconsistent with the ANSI recommendation.
The inspector also noted that because of the instrument's sensitivity to fluctuating background levels, there were some instances in the last two months where the WBC was unavailable.
The licenseo staff is currently reviewing this issue.
4.0 External Excosure Controls The inspector reviewed the exposure rate verification for the on-site gamma calibration sources.- These verifications are performed annually using a National Institute of Standards and Technology (NIST) traceable X-ray monitor or equivalent.
No deficiencies were noted in this area.
The inspector reviewed the calibration of survey instruments and the calibration of digital alarming dosimeters ( ALNORs ), The calibration programs for those instruments appeared to t ' be good.
A review of the licensee program for calibrating pocket. ion chambers was conducted.
The inspector observed that the licensee performs a 24 hour drift test with an acceptance criteria of plus-or-minus (+/-) 2 percent.
. ANSI N322-1977, " Inspection and Test Specifications for Direct and Indirect Reading Quartz Fiber Pocket Dosimeters", section 7.2.1 i ?
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states in part; that in the absence of radiation, the ion chamber shall discharge no more than 5% per 48 hours and that the test period shall equal or exceed 48 hours.
The inspector noted that the licensee reduced the discharge time by one half and the acceptance criteria by slightly . more than one half.
This practice would appear to be less > - time consuming-and more conservative.
However, there are two potential concerns regarding this practice.
The first concern is that-for a 200 mR ion chamber, an acceptance criteria of (+/-) 2% would be (+/-) 4 mR.
Typically, the smallest demarcation on the scale is 10 mR.
This would require-the technician to disco n between a dose of 4 mR and 5 mR, which is located between tus smallest demarcation interval.
The second concern is the implicit assumption that ion chamber discharge is linear over time.
Lacking any specific data,-this may or may not be a reasonable , assumption.
The licensee is currently reviewing the program requirements regarding this issue.
During a tour of the Dosimetry-Calibration Laboratory, located on the 23' elevation of the Reactor building, the -
inspector. found a l"Cs (approximately 150 mC1) calibration f wource that was unlocked.
A key cabinet present in the i room, containing.the padlock key to.the source, was also l found to be unlocked.
.The door to the calibration ' laboratory, containing both'the key cabinet and the calibration source,_was locked.
Following a review of the station ~ Technical Specifications and_the applicable proveaures, the. inspector determined that the licensee's-program did not have any requirement to lock calibration sources;when they are not in'use.
The inspector discussed this' incident with licensee management and concluded that .the locked laboratory. door was fortuitous.
If this door had 'been unlocked, the. licensee would have lost complete control Lof.this sourco.- The licensee evaluated-the-locks and agreed-Eto change the-program to include a requirement to lock calibration sources that are not in use.
The inspecter felt-the licensee's response to this incident was adequate and appropriate.
5.0-Plant-Tours LTours of the licensee's facilities-were conducted during the inspection.
Areas toured included the Reactor, Turbine, and
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, Radwaste buildings; and the whole body counting, instrument calibration,'and dosimetry calibration facilities.
The tours showed housekeeping within these areas to-be good.
Postings and access control to the controlled areas were also found to be good.
- 6.0 Audits and Acoraisals The' inspector reviewed the most recent in-house audit of the radiation protection program, Audit Report Number 90-33.
- This audit was conducted during the months of October and November.
Inspector review of the audit report indicated that a comprehensive audit had been conducted by well qualified individuals, including a Technical Specialist, from Yankee Atomic Electric Company (YAEC).
The licensee staff was responsive to the audit findings.
For example, the auditors identified a concern that access / egress to the Radiologically Controlled Area (RCA) may be inhibited if the > computer system, which supports the digital alarming dosimeters, is-unavailable.
The staff is developing an alternate-manual method for providing RCA access / egress.
The auditors also identified a-concern regarding the Turbine building vent monitoring system.
The staff is evaluating the monitoring system to address this concern.
The - < inspector noted that the auditors will be reviewing this issue in audit 91-06.
The inspector discussed this issue with licensee staff and asked the staff to demonstrate the adequacy of the monitoring system.
The results of the analysis will be reviewed during a future inspection.
The inspectof reviewed the licensee's summary of-Radiological Occurrence. Reports (RORs) for 1991.
There were.
a-total of 29 RORs written-by the end of this inspection.
The' inspector reviewed specifically ROR 91-01-23-0015.
This-ROR was generated when contamination was detected in a Radwaste building corridor _during a' job evolution in the , , l Spent Resin Tank Room.
The licensee evaluated the . ' [- ventilation flow path between the Spent Rosin Tank-Room and- . i the corridor in the Radwaste building as well as the ! radiological; hazards.
The licensee evaluation and corrective actions were considered to be appropriate.. There ~were no other.significant ROR findings and the licensee's corrective actions for the self identified occurrences was good.- Four QC surveillances have_been performed for radiation i . . .. .. .
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protection practices during 1991.
These surveillances scrutinized the operation of the Trash Compaction Facility (TCF).
The surveillances covered: the hazardous material storage area, the operation and control of the bag monitor, the operation of the waste press, the general building condition; and provided an inter-comparison of station procedures, related to the TCF, for consistency.
The cuditors performed a thorough surveillance and identified legitimate concerns.
The plant staff responded appropriately to these concerns.
The inspector felt that the surveillance observations and staff resolutions demonstrated a licensee willingness to be self-critical in this area.
8.0 Exit Meetina The inspector met with licensee representative at the conclusion of this inspection, on March 1, 1991.
The inspector reviewed the purpose and ecope of the inspection and discussed the inspection findings.
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