IR 05000311/1985012
| ML18092A624 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/24/1985 |
| From: | Cioffi J, Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18092A623 | List: |
| References | |
| 50-311-85-12, NUDOCS 8506030505 | |
| Download: ML18092A624 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /85-12 Docket N License N DPR-75 Priority Licensee:
Public Service Electric and Gas C P. 0. Box 236
---
Hancocks's Bridge, New Jersey 08038 Facility Name:
Salem Unit 2
Inspection At:
Hancocks Bridge, New Jersey Inspection Conducted:
1985 Inspector~/ :A"
- 1
/<. *
~v. Cioffi, -Radiation ecialist j
/211-~
r Dragoun:acITa~iO pecialist Approved by:./'J!!-~
M. Shanba Y,Chief~
Radiation Protection Section Category _c_
Inspection Summary: Inspection on April 15-19, 1985 (Report No. 50-311/85-12).
Areas Inspected:
Routine, unannounced inspection of the radiation safety program including:
status of previously identified items; internal exposure assessment; organization and staffing; routine radiological surveys; abnormal environmental sample; ALARA; calibration and maintenance of survey meters; and personnel dosi-metr The inspection involved 80 inspector-hours on site by two region based inspector Results:
No violations were identifie DETAILS Persons Contacted During the course of this routine inspection the following personnel were contacted or interviewed: Licensee Personnel L. Miller, Assistant General Manager, Salem Operations
- L. Fry, Operations Manager
- J. 0 1Connor, Radiation Protection Engineer
- W. Ferguson, Senior Supervisor Radiation Protection
- J. Johnson, Radiation Protection Services
- D. Perkins, Station Quality Assurance Engineer
- B. Smith, Associate Engineer
- D. Dodson, Licensing Engineer NRC Personnel
- R. Summers, Resident Inspector
- C. Woodard, Region Inspector
- Attended the Exit Interview on April 19, 198.
Purpose The purpose of the routine inspection was to review the licensee 1 s radia-tion protection program with respect to the following elements:
Status of Previously Identified Items
Internal Exposure Assessment
Organization and Staffing
Routine Radiological Surveys
Environmental Monitoring Abnormal Measurement
ALARA for a Coolant Pump Inspection
Calibration and Maintenance of Portable Survey Equipment
Personnel Dosimetry Status of Previously Identified Items (Closed) Followup Item (84-09-01) QA Audits per Technical Specifi-cation 6.5.2.8 to.review performance of the plant staf The audit
plans for 1984 and 1985 were revised to include a staff performance evaluatio.2. (Open) Follow-up Item (84-09-03) Implement revised radiation pro-tection procedure The licensee has shown progress but has not completed this projec.3 (Closed) Violation (84-13-03) Failure to post and control access to a very high radiation area (Skimmer Filter Room).
The licensee has installed locked gates and posted the room Action as described in PSE&G letter dated May 24, 1984 is complete and satisfactor.4 (Closed) Followup Item (84-21-01) Radiation Protection Services to issue ALARA Manua A manual was issued June 15, 198.5 (Open) Followup Item (84-21-02) ALARA Engineer to coordinate man-rem estimate ALARA procedure AP-7 requires ALARA Engineer review of refined exposure estimates for REP jobs but does not require specific engineer approval of the man-rem goa.6 (Closed) Followup Item (84-21-04) Expand procedure for response to CAM alar Procedures RP 8.031 and RP 8.042 have been revised to require additional air sampling and analysis in the event of an alar.
. Internal Exposure Assessment The adequacy of the licensees internal exposure assessment program was reviewed against criteria contained in:
10 CFR 20.103 Exposure of individuals to concentrations of radio-active materials in air in restricted areas
10 CFR 20.401 Record of surveys; radiation monitoring, and disposal
10 CFR 19.13 Notifications and reports to individuals
Regulatory Guide 8.9, Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Program
Regulatory Guide 8.26, Applications of Bioassay for Fission and Activation Products
ANSI N343, Standard for internal dosimetry for mixed fission and activation products
RP3.027 Whole Body Counting Frequency and Action Level *
RP 3.050 Operation of the APT Whole Body Counter
- RP 3.051 Calibration of the APT Whole Body Counter The licensee's performance relative to these criteria was determined from discussion with HP supervisors and a review of selected record The inspector noted that the semiannual calibration of the whole body counter is completed only by selected HP supervisors who possess the pass word to the protected computer analysis progra Eight various radioisotopes are used in mixtures placed in a phantom to align the multi-channel analyze These isotopes are used singly to establish the detec-tor efficiency factor The equipment is operated only by qualified senior level HP technician The inspector concluded that these measures ensure a high confidence in the internal exposure assessment The licensee stated that the responsibility for whole body counting will be re-assigned and the equipment relocated to a new processing center on or about July 198 This will be reviewed in a future inspection including new personnel qualifications and adequacy of new procedure.
Organization and Staffing The organization and staffing of the radiation protection department were reviewed against criteria contained in:
Technical Specification 6.2 Organization Technical Specification 6.3 Facility Staff Qualifications ANST Nl8.l-1971, "Selection and Training of Nucle:i.r Power Plant Personnel" Reg. Guide 1.8, "Personnel selection and training" Procedure AP2 Revision 4, "Station Organization" The licensee's conformance with these criteria was determined by a review of training and experience resumes of HP supervisors and a review of super-visors job description Within the scope of this review no violations were observed, however, the following improvement item was noted:
The licensee has significantly expanded the number of supervisory positions in the Radiation Protection Departmen This increase will allow increased management oversight of the various program areas within the departmen However, the in spec to)". --found that some job descri pt i ans were not yet issued, certain functional responsibilities were not assigned, some re-porting relationships were not changed to coincide with the new organi-zation and incorrect ANSI Nl8.l qualification requirements were referenced in the draft job descriptio The licensee stated that the organizational structure was in transition
and that these administrative oversights would be corrected prior to final implementation of the new organizatio This matter will be reviewed in a future inspectio (85-12-01) Routine Radiological Surveys The licensee~ radiation survey program to support work in radiologically controlled areas was reviewed against criteria in:
10 CFR 20.103 Exposure of individuals to concentrations of radio-active materials in air in restricted areas
10 CFR 20.201 Surveys
10 CFR 20.401 Records of surveys, radiation monitoring, and disposal
Technical Specification 6.10 Record Retention
Licensee procedures RP 1.013, RP4.001, RP4.002, RP4.003, RP4.004, RP3.036 and RP3.040 The licensee performance relative to these criteria was determined by:
Review of outage surveys conducted of Unit 2 steam generators between October 1984 and March 1985
Observation of technicians conducting surveys and a review of per-tinent records Within the scope of this review, no violations were observe An allegation was received by a Region I inspector on March 8, 1985 that records of alpha surveys performed in the steam generators at Salem had been falsifie The allegation was made by an individual.who had not worked at the Salem site since March 198 The inspector determined that programmatic weaknesses with the licensees alpha surveys had been identi-fied during 1983 in inspection reports 50-272/83-14 and 50-311/83-1 These weaknesses have been corrected by the license A review of current radiation protection procedures and records indicates that the alpha surveys are properly conducted and recorde The inspector concluded that the allegation is without basi.
Environmental Monitoring Abnormal Measurement In a letter dated March 4, 1985, the licensee advised the Regional Admi-nistrator that a sediment sample analyzed on May 21, 1984 indicated Co 60 and Co 58 levels greater than ten times the applicable control station value This analysis was confirmed on February 21, 198 The cause of these abnormal measurements was not clearly specified in the lette * Discussions with Radiation Protection Services personnel indicate that sediment sample SA-ESS-llAl may be taken anywhere in a 1000 ft. by 1000 ft. sector centered on the outfall of the discharge pipe The activity in sediment samples is greatly affected by the following factors:
channel dredging by the Army Corps of Engineers direction of the tide in the Delaware Bay during sampling and the season of the year sample location with respect to the ends of the discharge pipes penetration depth of the scoop into the sediment The licensee has attributed the variation in the measured sediment activity at this sample point to these factors rather than abnormal plant discharge The inspector reviewed the licensee~ analysis of the data for this sample point for a 5 year period and concluded that although the detected levels may be attributable to normal plant operations, the inspector concurs with the licensee's conclusions that these levels did not result from any abnormal plant discharge No regulatory limits for liquid discharges were exceeded.
ALARA for a Coolant Pump Inspection - Unit 1 The licensee had been experiencing a Coolant Pump Bearing Oil alarm on a Unit 1 pump for several week The alarm could not be correlated by other indications and was believed to be spuriou A management decision was made to visually inspect the pump oil sight glasses while maintaining the plant at 100% powe The licensee's precautions for this work were re-viewed against criteria in:
Administrative Procedure AP-7 11ALARA
- RP 1.011 Containment Power Entries RP 1.013 REP and EREP Usage RP 1.016 Issuance and Control of High Radiation Area Keys RP 3.030 Issuance of Neutron Dosimetry RP 4.004 Radiation Survey - Gamma Dose Rate RP 4.005 - Radiation Survey - Neutron The licensee's performance relative to these criteria was determined by:
discussion with supervisors review of worker briefings review of REP #264 observation of the containment entry and exit Due to commendable preplanning the containment entry was completed in a timely fashion and with minimum personnel exposur Within the scope of this review, no violations were identifie.
Radiation Detection Instrumentation Calibration and Use The licensee's program for calibration and use of portable radiation detection instrumentation was reviewed against the criteria in:
10 CFR 20.201, "Surveys" 10 CFR 20.202, "Personnel Monitoring" 10 CFR 20.401, "Records of Surveys, Radiation Monitoring, and Disposal" ANSI N323-1978, "American National Standard Radiation Protection Instrumentation Test and *calibration" RP 3.060, "Operating Instructions for the 5.7 Ci AmBe Neutron Calibration Source," Revision RP 3.005, "Calibration of Self-Reading Pocket Dosimeters," Revision RP 3.044, "Operating Instruction for the Shepherd 3 Curie Model 81 Source Tower," Revision RP 9.038, "Calibration of the R0-2 and R0-2A Ion Chamber."
Performance relative to these criteria was determined by inspection of the the maintenance and calibration facilities, verification of current cali-bration of the various instruments used in performing surveys; discussions with Health Physics supervisors and technicians; a review of records at the instruments issue point; and an observation of the repair and cali-bration of an R0-2 ion chamber mete The licensee maintains a well-designed and properly shielded calibration facilit Radiation monitors and alarms are installed to warn personnel when the calibration source is in an unshielded configuratio Ad-ditionally, automatic interlocks, by photocell inactivation, initiate source shielding when personnel enter the vicinity of the exposed source
- during calibratio The personnel interviewed appeared to be thoroughly trained and familiar with the instrumentation and current procedure No items of noncompli-ance were identifie.
Personnel Dosimetry Program The licensee's program for personnel monitoring was reviewed against the criteria contained in:
10 CFR 20.202, "Personnel Monitoring" 10 CFR 20.401, "Records of surveys, personnel monitoring, and disposal ANSI Nl3.ll-1983, "American National Standard for Dosimetry -
Personnel Dosimetry Performance - Criteria for Testing."
Performance r~lated to these criteria was determined from interviews with the dosimetry supervisor; review of sections of the dosimetry manual, the computer software, equipment calibrations and quality control trending; and a review of the following procedures:
RP 3.030, "Issuance of Neutron Dosimetry," Revision 2 RP 3.056, 110peration of the Panasonic Model UD-710 A Reader," Revision RP 3.057, 11 Element Correction Factor Determination for Panasonic Personne 1 Issue TLD Materi a 1,
RP 3.058, "Calibration of the Panasonic UD-710 Automatic TLD Reader RP 3.059, "Fade Correction for Panasonic UD-802 TLD Badges."
Draft procedure, "Spiked TLD Badge Program" Draft procedure for resolving differences between TLD results and SRO reading.1 Organization of the Dosimetry Program The licensee changed over from the Harshaw dosimetry system to a new personnel dosimetry system, supplied by the Panasonic Industrial Company in January, 198 The Dosimetry group is part of the Radiation Protection Services group in the Nuclear Services Department, a corporate organizatio This group provides dosimetry services to both the Salem and Hope Creek generating station The service includes issuing, processing, and terminating personnel TLDs; and maintenance and management of
.*
exposure record The licensee is developing a dosimetry manual for NVLAP accredita-tion, which clearly delineates operating philosophy and organiza-tional responsibilitie.2 Qualifications and Training of Personnel Currently, the dosimetry supervisor is the only individual to have received formal training in Panasonic dosimetry use and processin A staff Health Physicist is scheduled to attend the next Panasonic training session, and the licensee plans to schedule formal in-house training for all clerical dosimetry personnel in order to meet NVLAP accreditation requirement The licensee has included a well defined training requirement section in the draft dosimetry manual for this group which specifies formal dosimetry training and annual requalification training for all dosi-metry processing personne.3 Facilities and Equipment The licensee currently maintains two Panasonic model UD-710A dosi-meter readers for processing personnel dosimetr Data from the readers is transmitted to a Hewlett Packard model 1000 A computer where the information is recorded on parallel hard disks and tape using the Panasonic TLD System progra Information from the TLD processing is then transferred to hard disk and tape using the Per-sonnel Radiation Exposure Monitoring System (PREMS) software for personnel dose assignment and recordkeepin The licensee is using the Panasonic model UD 802 thermoluminescent dosimeter (TLD) with the Panasonic model 874 hanga The design is as follows:
Element Phosphor Filtration (milligrams per square centimeter)
El E2 E3 E4 Lithium Borate 14 (mylar, phosphor)
Lithium Borate 320 (plastic, phosphor)
Calcium Sulfate 320 (plastic, phosphor)
Calcium Sulfate 1020 (plastic, lead, phosphor)
An algorithm was developed for the licensee by Phil Plato, In The algorithm was developed using two cesium-137 beam irradiators and two
- General Electric X-ray machines as the photon source The beta particle sources include strontium-90 and thallium-204 irradiator A heavy water moderated californium-252 source was the neutron sourc The algorithm was developed to meet the requirements of the ANSI N 13.11-1983 standard on personal dosimetry performanc The licensee determines deep dose with element 2 of this dosimete~;
however, element 4 is used to assign deep doses under 25 millire Element 3 is used for comparison purposes with element 2 and element 3 and 4 are used to characterize the type of photon energy.*
Element 1 is used to assign shallow dos Additionally, elements 1 and 2 have been incorporated into the algorithm for neutron dosimetry due to the type of phosphor used (natural lithium borate) and its excellent response to neutron However, the licensee is using the Landauer Neutrack ER dosimeter as the dosimeter of record for deter-mining dose to neutrons along with actual neutron remmeter measure-ment The licensee is still developing the upper and lower limits of detec-tability of the dosimeter The manufacturer has stated that the lower limit of detection for calcium sulfate is 1 millire The upper limit of detection based on the lithium borate element is 999 re The licensee currently assigns doses as low as 1 millirem for personnel exposure record The licensee has empirically determined fading factors for the TLDs to be used in special circumstances when personnel dosimetry must be read immediatel Th~ written procedure states that the dosimetry supervisor will determine when and what fading factors are to be used in such circumstance The inspector toured the facilities used by the licensee for the processing of personnel dosimetr A room has been dedicated for this purpose and bench space and other services appeared adequat The entire dosimetry department is scheduled to be moved in the near
- future to the Central Guard Hous This facility has been designed to ensure that dosimetry processing will not be affected in the event of an emergenc.4 Quality Assurance/Quality Control The licensee performs calibrations on TLDs with a 3 curie cesium-137 calibration source in the calibration facility, equipped with the appropriate monitors, interlocks, and alarm A Victoreen R-Chamber is used to measure the delivered dos Plaques of promethium-147,*
thallium-204, and strontium/yttrium-90 have been purchased for beta calibrations of the dosimetr The TLD reader is checked daily using TLD badges that have been given
- a low dose of radiation (approximately 200 to 300 millirem) and blank badge Badges given a large dose (approximately 5 rem) are read to check the TLD reader on a monthly basi If the data varies by greater than +/-10%, the reader is re-calibrate Daily quality control checks are plotted and analyzed for potential system degradatio A draft spiked sample procedure has been written for additional quality assurance of the dosimetry measurement The draft procedure states that at least one spiked TLD badge will be processed for every 500 badges processe If the reported dose equivalent varies from the delivered dose equi-valent by more than 15%, the dosimetry supervisor will investigate the cause of the discrepanc At the present time, all results of the spiked samples will be retained to provide indications of reader degradation and reproducibility over tim Element correction factors (ECFs) were initially determined for all TLDs and will be checked annually to spot problems with TLD element performanc The licensee decided that differences of no more than
+/-10% from the original ECF values will be acceptabl At the present time, the licensee also generates glow curves on all processed badge The glow curves of any element having a dose of greater than 25 millirem are saved on hard disk and tap These records can then be accessed at a future time in the event of pro-blems with that dosimeter elemen.5 Dosimetry Processing The licensee processes all dosimetry for Salem on a monthly basi The dosimetry department currently processes about 2000 badges per mont An additional 2000-3000 badges is anticipated for proces-sing when Hope Creek loads fuel:
TLDs for Salem are exchanged by the in-plant radiation protection
- grou Dosimeter losses for Salem are recorded on a Radiological Occurrence Report (ROR).
An Unusual Incident Report (UIR) is gene-rated and kept by the dosimetry department which records the evalua-tion of the dose of the individual whose dosimetry was los The UIR additionally allows for re-evaluation of dose if the assigned dose is questione The results of dosimetry processing are recorded on a hard disk and back-up tape using the Personnel Radiation Exposure Monitoring System (PREMS).
This program stores all personnel exposure record The dosimetry processing procedure is being revised to list the steps the dosimetry processing personnel must take prior to loading the TLDs into the reade One step will include a contamination check on
.. *.
the badges prior to processin This is currently done by the in-plant radiation protection grou.6 Dose Assessment A daily assignment of deep dose is recorded on the Personnel Radia-tion Exposure Monitoring System (PREMS) by station health physics personnel based on self-reading dosimeters (SRDs).
These dose as-signments are replaced monthly by TLD deep dose reading However, if the TLD reading differs from the SRO reading by +/-20%, the computer software flags the discrepancy and this is brought to the attention of the dosimetry superviso A draft procedure for differences between SRO and TLD readings has been writte It is expected that discrepant data will be reviewed by station health physics personne At this time, however, the dosimetry department conducts the review and, if the differences cannot be resolved, the most conservative number is recorded on the personnel fil Extremity dosimetry is assigned by station health physics personnel for special working condition The licensee uses the Panasonic TLD badge adapted for the wrist and ankl The assignment of dose from extremity monitoring is currently performed manuall A computer program is being written to perform and record the assignment of extremity monitoring for personne There were no items of..non-compliance identified in this revie.
Site Access On several occasions the licensee was advised of the need to provide ex-pedited unfettered site access for Region I Inspector During this inspection delays were experienced, particularly with security photo-badgin The licensee has issued internal memoranda and special instruc-tions in an attempt to resolved the delay However, these efforts have been unsuccessful. The licensee stated that this matter will be reviewed again and appropriate steps take This problem will be reviewed in a future inspection, (85-12-02).
1 Exit Interview The inspector met with the licensee personnel denoted in section 1 at the conclusion of the inspection on April 19, 198 The scope and findings of the inspection were discussed at that tim At no time during this in-spection was written material provided to the licensee by the NRC inspec-tion.