ML20207E529
| ML20207E529 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/18/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM NLR-N86197, NUDOCS 8701020199 | |
| Download: ML20207E529 (27) | |
Text
Pubhc Service b
Electric and Gas Company Carbin A. McNeill, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Vice President -
Nuclear December 18, 1986 NLR-N86197 United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Attention:
Thomas T. Martin, Director Division of Reactor Safety and Safeguards Gentlemen:
NRC INSPECTION 50-354/86-45 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company has received the subject inspection report dated November 18, 1986 which identified eleven (11) Open Items regarding the implementation of NUREG-0737, items II.B.3, Post Accident Sampling Capability, II.F.1-1, Noble Gas Effluent Monitors, II.F.1-2, Sampling and Analysis of Plant Effluents, II.F.1-3, Containment High-Range Monitor and III.D.3.3, Improved Inplant Iodine Monitoring.
PSE&G has either planned or taken actions in response to the identified deficiencies and the other commitments made by PSE&G during the course of the inspection (noted in Section 10.0 of the inspection report).
Attachment A to this letter identifies those corrective actions which are planned or have been taken as requested in the cover letter of the inspection report.
Should you have any questions with regard to this transmittal, do not hesitate to call.
Sincerely,
/
Attachments g[g h 10 P
$[CT C31 dl
Mr. Thomas T. Martin 2
12-18-86 C
Mr.
D.
H. Wagner USNRC Licensing Project Manager Mr.
R.
W.
Borchardt USNRC Senior Resident Inspector
ATTACHMENT A PSE&G RESPONSES TO NRC INSPECTION REPORT 50-354/86-45 OPEN ITEMS OPEN ITEM 50-354/86-45-01 Reactor Coolant Sampling improvement items
RESPONSE
a.
Sample needles were bent during the first attempt at taking an undiluted reactor coolant sample.
PSE&G has reviewed and evaluated the sample vial positioning and alignment.
A change to the positioning and alignment shall be completed under Design Change Request (DCR) 4-HMM-86-1325 in the second quarter of 1987.
b.
The liquid sample vial septum retaining ring was damaged (split) during sampling to the extent that it no longer retained the septum.
The split retainer ring used in the large volume undiluted sample has been changed to a non-split retainer ring.
This has been revised in Procedure CH-EO.SH-001(0).
Additional precautions requiring checking the condition of the vial immediately after the sample has been withdrawn into the lead pig have been incorporated into CH-EO.SH-001(0).
OPEN ITEM 50-554/86-45-02 Containment Air Sampling improvement items
RESPONSE
a.
Suitable silver zeolite cartridges were not available at the Hope Creek site for airborne iodine sampling.
Also, the churcoal cartridges used during the test were not purged.
Chemistry has placed silver zeolite cartridges on storeroom folio 31-9643.
The General Electric PASS is designed with purging capabilities after the sample has been taken allowing for noble gas activity to be purged from the cartridges.
This is contained within procedure CH-EO.SH-001(0), step 5.2.8.29.
b.
The PASS sampling procedure does not specify whether to use the air sampler rotameter or the tiow maintained by the limiting flow orifice in calculating airborne particulate and iodine activity.
Chemistry uses the air sampler rotameter in accordance with Procedure CH-EO.SH-001(0), steps 5.2.8.26 and 5.2.8.27.
The total volume through the cartridge and particulate filter is calculated on Attachment 4 of the procedure.
c.
The PASS sampling procedure requires that an airborne particulate and lodine sample be taken for a preset time rather than allowing the technician taking the sample to vary the time based on the amount of radioactivity being collected on the sampling media.
The entpoint of the process radiation monitor for the drywell sample will be lowered to less than or equal,to 50 mR/hr to serve as an alert to chemistry personnel to cease sampling.
This action will be completed by January 31, 1987.
Chemistry Procedure CH-EO.SH-001(0) has been revised to call for sample size limitation when there is a rapid climb in the panel process monitor reading.
OPEN ITEM 50-354/86-45-03 Chloride analysis improvement items
RESPONSE
a.
PSE&G was found not to be a registered user of the shipping cask which was designed for shipping of PASS undiluted liquid samples.
Also, there were no procedures for sample loading and closure of the cask.
Pursuant to the requirement of 10CFR 71.12, PSE&G requested to become a registered user of the PAS-1 NUPAC cask on October 7, 1986.
Since that time, we have received the vendor manuals from both the Pooled Inventory Management System (PIMS) group and from NUPAC and these manual documents are now controlled by the engineering department.
A procedure for PAS-1 cask use has been written and either the procedure or the vendor manual will be used as a temporary procedure when (and if) the cask is used.
b.
PSE&G had not established maximum dose rate criteria for use in determining when a PASS liquid sample can be analyzed onsite without exceeding GDC-19 criteria.
Chemistry Procedure CH-EO.SH-004 has been revised to provide the abort point above which onsite chloride analysis will not be performed.
The trigger level for this is 50 mR/hr contact on the vial.
This value is based on the fact that the ion-chromatograph equipment is outside the shielded hood setup for other PASS wet chemical analyses.
Samples with contact doses exceeding this value will be shipped to Babcock & Wilcox for analysis.
OPEN ITEM 50-354/86-45-04 PSE&G will review core damage assessment methodology to ensure that appropriate radionuclides are determined in order to implement the core damage estimate procedure (CH-T1.22-Oll(0)).
RESPONSE
a.
Revisions have been made to CH-EO.SH-004(Q), PASS Post-Accident Sample Analysis, to include a gamma scan printout as an attachment to the procedure.
The Chemistry Coordinator may use the nuclides contained within CH-TI.ZZ-Oll(Q) off the printout to calculate core damage.
OPEN ITEM 50-354/86-45-05 The procedure for performing dissolved gas sampling at the PASS did not provide guidance for reinitiating sample flow following the collection of a liquid sample.
RESPONSE
a.
Chemistry has revised Procedure CH-EO.SH-001(Q) to clarify the steps and provide guidance for reinitiating sample flow for dissolved gas sampling.
Procedure was revised and technicians were retrained on that portion of the procedure.
OPEN ITEM 50-354/86-45-06 Other PASS improvement items
RESPONSE
a.
Technicians which were assigned to perform the PASS sampling during the inspection were not qualified on the use of SCBAs.
All seventeen chemistry technicians and assistants who may be called upon to take a PASS sample were qualified in the use of SCBAs as of October 20, 1986.
b.
Dose limits had not been established for removing the transport shield and handling an undiluted vial of reactor water in the chemistry laboratory.
PSE&G has established that samples that can be diluted will be diluted for handling and analysis within the chemistry laboratory.
For sample analyses that may not be amenable to dilution (e.g., pH ), it is prudent to set a maximum allowable dose rate for the sample.
Using the worst case coolant scenario, calculation indicate that the quarterly extremity dose limits could be approached (not exceeded).
The whole body dose is not limiting for this activity under design basis accident conditions.
Therefore, a maximum allowable dose rate of 500 mR/hr outside the cask is being evaluated as a potential criteria.
This value represents a scenario about 50% of the design basis case and would provide a significant margin of safety for meeting GDC-19 criteria.
However, based on the GDC-19 analysis of time and dose, the design basis accident case meets the design criteria.
c.
The tongs used for removing the containment gas sample vial from the sample vial holder did not work.
The tongs have been modified to allow the analyst to remove the vial without difficulty and transport it to the shielded cask in keeping with ALARA practices.
OPEN ITEM 50-354/86-45-07 Noble Gas Effluent Monitor improvement items
RESPONSE
a.
The use of CRCONV, a computer program used to correct detector response to total concentration, in the dose assessment procedure needs clarification.
PSE&G feels that the existing dose assessment procedures (manual and computer) provide the necessary conversion from total noble gas concentration to dose.
The appropriate CRCONV conversion factors within the RMS channel setpoint have been installed.
b,c & d The inspector requested verification of the concentrations of Xe-133 and Kr-85 used by the vendor in the original type test of the RD-72 detectors, the linearity of the RD-72 5
detectors as they approach maximum concentration of 10 uci/cc and the reproducibility of the volume viewed by the high-range detectors as installed in the shield.
The Hope Creek RD-72 detectors (high-range effluent
- hannels) have been calibrated in accordance with the vendor's methodology utilizing NBP. traceable transfer sources and are considered to be fully operable.
- However, the inspectors expressed specific conerns with respect to the vendor's type calibration of the RD-72 detectors.
These concerns will be addressed by conducting site tests which are beyond the normal requirements for radiation monitoring system startup.
Specifically, site testing will consist of utilizing gaseous Xe-133 and Kr-85 sources for at least 2 concentrations per channel to verify the detector linearity through the count rate region required to achieve the stated 105 uci/cc channel range.
This testing will be used to verify gaseous efficiencies, detector linearity, and the reproducibility of the high-range chamber volume to supplement the vendor supplied test data.
At the current time, all six RD-72 installed at Hope Creek have been calibrated using not only the vendor's sources, but also sets of NBS traceable gamma and beta disc sources to verify detector energy response.
In addition, the 5
linearity of each channel has been tested in excess of 10 CPM using solid Sr-90 disc sources.
To implement the additional testing, a new site temporary procedure RP-TE.SP-012(Q) will be written prior to December 31, 1986.
This procedure will be reviewed by site Radiation Protection staff members to assure that ALARA is practiced in the source handling.
Required test fixtures and sources will also be specified during procedure development and review.
Following the selection of appropriate test fixtures and sources, these items will be purchased with delivery scheduled to avoid excessive source decay prior to use in the calibrations.
Since testing of these channels could interfere with normal effluent monitoring, these act:ivities must be scheduled within the restraints of plant oparation. Due to the relatively high concentrations of Xe-133 and Kr-85 gas required for testing, this testing will only be conducted following careful fabrication of a test loop for gas handling.
Similarly, a special source holder must be fabricated prior to use of the largest linearity test source to reduce personnel exposure.
With reasonable source delivery times and test fixture fabrication times, those testing activities are expected to be completed by March 31, 1987.
1 The inspectors suggested that PSE&G consider regular e.
verfication the database setpoints for these monitors.
PSE&G is developing a computer program to provide verification of database setpoints on a regular basis.
Procedure RP-AP.SP-001(Q) will be revised by January 31, 1987 to require verification of all Tech Spec related setpoints at least weekly, and all non-Tech spec related setpoints semimonthly.
f.
The inspector suggested that PSE&G consider the maintenance of a list of required spare parts for the Radiation Monitoring System.
The Hope Creek Station planning department currently retains a list containing more than 300 line items of spare parts.
OPEN ITEM 50-354/86-45-08 Improvement items for sampling and analyses of plant effluents
RESPONSE
a.
The inspector suggested that the north and south plant vent Skid operation procedure be revised to provide for the locally controlled collection of a brief grab sample in the idle sample position.
The vont sample collection procedure RP-TI.SP-003(0) is being revised to include a sample volume (i.e.,
time sampling) limitation based on Noble Gas concentration readout (i.e.,
less than 30 seconds of sampling time in Noble Gas concentrations exceeding 1 uCi/cc).
Procedure revision will be completed by January 31, 1987.
Note:
The procedure was incorrectly referenced as (RP)ST-003(0) in the inspection report, b.
The inspector suggested modification of the FRVSV skid operation procedure to limit the time of the first post-accident grab sample to f acilitate its removal from the shield and its transport.
Procedure RP-SO.ST-002(0) will be revised by January 31, 1987 to limit the time of the first grab sample that is obtained following the onset of post-accident concentrations of radiogases.
Note:
The procedure was incorrectly referenced as RP-ST-004(O) in the inspection report.
c.
The inspector suggested that spare loaded particulate filter and iodine cannister holders be provided so that the sample holder does not have to be unloaded by hand to install a fresh particulate filter and iodine cannister.
Spare particulate filter and iodine cannister holders are currently available onsite for installation on the skids subsequent to filter holder removal.
d.
The inspector suggested a revision to the north and south plant vent skids operation procedure to require that samples be purged prior to their transport.
Procedure RP-TI.SP-003(0), Operation of the NPV and SPV Skids will be revised by January 31, 1987 to include purging of samples using a portable nitrogen source prior to sample transport.
c.
The inspector suggested that a supplementary readout location for the FRVSV be provided so the person performing the sample will have a local readout.
PSE&G has evaluted the need to re-locate the FRVSV Area Radiation Monitor (ARM).
Because the annunciator for the ARM is in close proximity to the skid and the technician is performing the sample changeout will have a portable dose rate instrument in his/her possession, ARM local readout relocation is not required.
In addition to using portable dose rate survey instrumentation, technicians obtaining samples normally have in their possession portable radios such that they are in constant communication with personnel at the 137' Elevation Control Point.
Personnel at the Control Point have access to the RM-ll Console where they can obtain FRVSV skid and ARM radiation data.
OPEN ITEM 50-354/86-45-09 Containment High Range Monitor improvement items
RESPONSE
The inspector noted that the Containment High Range Monitor a.
was not described in alarm response procedures.
Procedure OP-AR.Z Z-Oll(O) is being revised to address this concern.
The estimated issue dato of this procedure revision is January 31, 1987.
b.
The monitor surveillance procedure (IP-CC.SP-041(O)) does not verify alarm annunication (signal transfer from the RM-80 to the RM-ll).
This procedure will bo revised to include verification of alarm annunciation by January 31, 1987.
c.
Documentation was not available to substantiate qualification of the installed cable / connector information.
General Atomic Test Report E-254-960 dated May 1, 1981 considered Raychem WCSF-N to be a prequalified material based upon Franklin Research Laboratories - Final Report F-C4033-3 and the Raychem Energy Division Report Number EDR-5019.
The subject of these reports were cable splices and did not include metallic olectrical connectors.
Further study has revealed that Conax Corporation Design Qualification Test Report IPS-1054 has included the Amphenol 82-816 HN Connector (metallic) protected by Raychem WCSF-N shrink tubing as a qualified configuration.
A safety evaluation performed by PSE&G Engineering has esablished the similarity between the tested configuration and the Hope Creek configuration.
This safoty evaluation has established that the high range containment monitor cable assembly is qualified to Hope Creek environmental and Design Basis Earthquake conditions for a service life of 22 years, after which the outer WCSF-N tubing is to be replaced (assuming maximum temperature conditions prevail throughout the entire 22 years of use).
OPEN ITEM 50-354/86-45-10 Improvement items for In-Plant Iodine Instrumentation Under Accident Conditions
RESPONSE
a.
The inspector roquested that the acceptability of the methods used by PSE&G to dotormino the officiency of SAM-2 single channel analyzor be ovaluated or that the method be changed to provide a geometry which is more consistent with the iodine deposition to bo expected (i.e. faco loaded, uniform iodino deposition).
A face loaded uniform " calibration" zeolito cartridge has boon ordored from our vondor which will alloviato potential geomotry problems associated with the counting of thoso samplos.
The anticipated delivery dato is Janaury 15, 1987.
b.
The incp ctor cugg:sted thet "hnnds on" training with emergency sampling equipment be provided ao opposed to the current practice of procedure walk throughs with some hands on training being given during emergency exercises.
" Hands-on" training is being provided for set-up and operation of emergency sampling equipment including the use of the 9.5 liter Marinelli beaker with vacuum pump and SAM-2 single channel analyzers.
As of December 5, 1986, 19 out of 25 Radiation Protection technicians had received this training.
c.
The inspector identified a number of deficiencies related to the Emergency Procedures which address NUREG-0737 Item III.D.3.3 (EP IV-112 and EP-IV-ll3).
The following changes were made to these procedures in response to the inspectors comments.
The affected pages are attached (seo Attachment B):
1)
The locations for samplo pumps were indicated to be at the 137 foot elevation locker, the 124 foot control room /OSC locker and the TSC.
(See Step 3.12, Pago 1 of Attachment B).
2)
A minimum sample volume for low volume air samples is provided.
The time period is 30 minutes for an MDA of 25% MPC I-131, or for a shorter duration at the direction of the Radiation Protection Coordinator or his designeo.
(Sco Step 3.14.2, Page 2 of Attachment B).
3)
The sample " turnover" requiremont to ensure the Radiation Materials Coordinator receives samplos is to turn in the sample to the RMC or his designee directly.
(Sco Step 3.17, Page 2 of Attachment B).
4)
The samplo documentation requirements are clarified and described by reference to the proper attachments for a Marinolli air samplo and an air samplo analysis work shoot.
(Soo Stop 3.11 and 3.11.1 and referenced attachments, Pages 3-6 of Attachmonmt B).
5)
An " abort-point" or hold point is defined in reference to EP IV-104 Section 3.10, which instructs development of hold points based on the procoding stops of that proceduro.
(Soo Step 3.13, Page 7 of Attachment B).
6)
The nitrogon purgo location for purging samplo cartridges is in a place that will facilitate exposure reduction and not interfero with tho measuromonts in progress (Sco Stop 3.12.2, Pago 8 of Attachmont B).
7)
The terms "habitablo/ accessible" woro defined as low background areas (1 0.5 mR/hr.).
~,
8)
The maximum allowable background to count / analyze sample cartridges is defined as < 0.5 mR//hr.
(See Step 3.12.2.b, Page 9 of Attachment B).
9)
The survey geometry used for estimating iodine deposited on charcoal cartridges was described as closed window, cartridge inlet side up and at the center of the cartridge.
A diagram was also provided (See Step 3.12.4.b, Page 9 and 10 of Attachment B).
- 10) The dose rate criteria for selecting a method to analyze a sample based on size of source and geometry was revised.
From NUREG-4297 (source size correction factors) a correction factor of 0.6 was determined and incorporated, changing the hold point of 5 mR/hr to 3 mR/hr.
(See Step 3.12.3.a, Page 9 of Attachment B).
- 11) An equation for determination of iodine airborno activity when using the SAM-2 was established and is included in the proceduro.
(See page 6 of Attachment B).
- 12) The location of Ba-133 check sources for verifying efficiency of SAM-2 was identified as the Control Point locker at the 137 foot elevation (See Step 91, Page 12 of Attachment B).
- 13) The minimum acceptable vacuum required for use of the 9.5 liter evacuated Marinelli is identified as 20 inchos mercury (See Step 3.11.2, Page 1 of Attachment B).
- 14) Geometry of cartridge when using the SAM-2 is described.
The geometry is inlet sido down (arrows pointing up) and is diagramed.
(See Step 91, Page 10 and 12 of Attachmont B).
- 15) Acceptable sample storago locations are described and referenced in EP IV-111 as the sample storage cavo and or a lead pig (Soo Steps 3.0 and 4.1, Page 13 and 14 of Attachment B).
d.
Procedure RP-SA.22-002(0), Airborno Radioactivity Analysis was missing from the controlled proceduros in the llope Crook Technical Support Centor (TSC).
The set or controlled Radiation Protection proceduros located in the main TSC area is not a comploto set.
This set includos selected procedures which may provido guidanco to Radiation Protection pornonnol assigned to the TSC.
Maintenanco of a controlled copy of the Airborne Radioactivity Analysis proceduro within the TSC is neither
^
appropriato nor necessary.
Ilowever, it should be noted that two (2) comploto controlled sets of Radiation Protection proceduros are located in the upper level of the TSC (flope Crook Radiation Protection offico area) for uso, if noodod.
e.
The inspector noted that Procedure RP-TI.ZZ-031(0) is referenced in Emergency Procedures but that this procedure has not been formally ostablished and approved for use.
The purpose of this procedure is to replace a current chemistry sample analysis procedure.
RP-TI.ZZ-031(Q), Gamma Spectroscopy Counting is being developed and is scheduled for completion on February 1, 1987.
f.
The inspector suggested the dodication of additional SAM-2s in the omorgency lockers of the Hope Creek Emergency Responso Pacilities.
SAM-2s will be added to the lockers in the Control Room and TSC in addition to the SAM-2 which is already available at the control point.
Additional SAM-2s are also availablo at the instrument issuo room on the 124' olevation.
OPEN ITEM S0-354/86-45-11 QA and Dosign Review improvement items
RESPONSE
I a.
Applicablo proceduros did not address actions required to ensure the availability of tho elevator which is used to transport the PASS samplo to the chemistry laboratory.
Emergency Proceduro EP IV-204 has boon revised to stato that the Chon.istry Activities Coordinator shall be responsible for notifying the Control Room to onorgizo elevator 31-04 via motor contol contor MCC-00B474.
Proceduro CH-EO.SH-007(0) (for transporting the PASS sample) will be revised by January 31, 1987 to include a precaution that the Chemistry Activities Coordinator ensure that olevator 31-04 is appropriately onergized prior to transportation of the PASS sample.
b.
The PASS Operation and Maintenanen Instruction Manual dated November 1981 did not reflect as-built design changos which have boon proscribed by the manuf acturer (General Electric) and incorporated into the system.
PSE&G has discussed this with the manufacturor.
Gonoral Electric is to provido an updated manual which incorporatos all of the aforomantioned changos/ revisions by December 31, 1986.
c.
The inspector requestod clarification of the calibration requirements for PASS panol instrumontation.
Hopo Crook FSAR Section 9.3.2.3.2, item J.6 states that "oquipment used for post accident sampling analysis will be calibrated or testod approximatoly ovary six monthu."
In kooping with this commitmont, tost sampling is performed ovory six months by the Chemistry departmont to dotormino
the accuracy of the equipment.
If problems are encountered, appropriato instrumentation will be recalibrated at that time.
Otherwise, those instruments which are necessary for PASS sampling are calibrated overy 18 months.
d.
The inspector suggested that an adaptor be developed to facilitato the operation of PASS panel control switch HC-652.
An adaptor to provide the additional loverage required to facilitate the rotation and holding of control switch HC-652 will be incorporated into the PASS panel in accordance with Design Chango Roquest (DCR) 4-HME-86-1326.
This DCR is projected for completion in the first quarter of 1987.
OTHER COMMITMENTS PSE&G mado several other performance related commitments during the courso of the inspection.
The commitments mado and related responsos are as follows:
a.
The Chemistry department was to issue a directive providing specific guidance relative to the certification of personnel for operation of the PASS.
Chemistry Directivo CH-DD.ZZ-018 was writton and implemented on September 29, 1986.
b.
PSE&G committed to revise the PASS proceduro by September 29, 1986 to provido clear guidance for dissolved gas sampling.
Proceduro CH-80.SH-001(Q), Revision 4 was revised by September 29, 1986 and approved on October 1, 1986 to include clarification of dissolved gas sampling and resolution of performance-related probloms identified by NRC during observation of dissolved gas sampling.
c.
PSE&G committed to qualifying at least one Chemistry Technician or Chemistry Assistant por shift in the revised PASS proceduros prior to startup subsequent to the end of the inspection.
PSE&G also committed to qualifying all Chemistry Technicians and Chemistry Assistants in the revised proceduros by October 10, 1986.
Prior to startup subsequent to the end of the inspection, at least uno Chemistry Technician or Chomistry Assistant was qualified.
All Chemistry Technicians and Chemistry Assistants woro qualified on PASS by November 26, 1986.
The October 10, 1986 dato was not mot because of testing rostrictions on equipmont imposed by the Hopo Crook Power Asconsion program.
d.
PSE&G committed to complcting Salf Containsd Brocthing Apparatus (SCBA) training for Chemistry Technicians and Chemical Assistants by November 12, 1986.
All Chemistry Technicians and Assistants were SCBA qualified by October 20, 1986.
e.
PSE&G committed to providing " hands-on" training in use of the in-plant lodine sampling equipment for at least one Radiation Protection technician per shift prior to startup subsequent to the end of the inspection.
PSE&G also committed to providing this training for all Radiation Protection technicians on an expedited basis.
Prior to startup subsequent to the inspection at least one Radiation Protection Technician per shift had received
" hands-on" training in the use of in-plant iodine sampling equipment including the 9.5 liter Marinelli beakers with vacuum pumps and the SAM-2 single channel analyzers.
Training for other Radiation Protection Technicians is continuing.
I i
1
ATTACHMENT B
PAGE 1 EP IV-ll2 Pg. 3 of 9
=
JL - 4 5'- NDC 'l3 3.11.1 Use only a Marinelli beaker which has 20" Mc or more of vacuum pressure.
EPIV-113 provides correction table for values less than 30" Ho.
3.11.2 For beakers less than 20" HQ or to incre'ase pressure obtain a vacuum pump from 124' l
elevation, instrument issue room.
Disconnect filter holder assembly from stopcock.
Attach vacuun pump to stopcock opposite vacuum cauge (Attachment 1).
Start pump and evacuate Marinelli between 20" and 30" Hg.
Close stopcock before shutting pump or removing hose.
3.11.3 Obtain from 137' elevation locker a samplino head.
Check for Radeco filter /cartridae l
holder, particulate filter paper and silver zeolite cartridge, and connect this assembly to the valve of the above Marinelli heaker.
Note: The entire assembly may already be pre-assembled. Check 0-rinos of the Radeco holder and carefully clean them, if necessary, to ensure an air-tight seal.
3.11.4 Attach the sampling head to the Marinelli beaker and hand tighten to ensure an air-tight fit.
The airticht integrity of this sampling system is critical due to the small size of the air sample to be obtained.
A small air leak could completely invalidate the results of the sampling leading to subsequent unnecessary exposures or over-exposure to workers.
3.11.5 Bag the sampler assembly leaving only the fil-ter holder exposed to prevent contamination of the outside of the Marinelli heaker (which could cross contaminate the H.P.Ge detector during analysis.)
[G-- 9f-lC L -l 3.12 For only iodine determination, use a low volume air 29 - 9 7 - 10 F sampler with battery pack (H-809 R2).
Both are obtained at 117' locker, 124' CR/OSC locker, and at TSC.
Check charge on battery pack by turning it on.
If it is not charced obtain another from above locations or 124' instrument issue room.
Ilse for locoina data.
HCGS Rev. 2
PAGE 2 EP IV-ll2 Pg. 5 of 9 8(o-U- /OC -3 3.14.2 For the low volume air sampler, turn the instrument on and ensure flow meter is operating.
Note the flow rate on Attachment 3.
Run the sampler for the time period of 30 minutes for an MDA of 25% MPC I-131 or for shorter duration at direction of RPS/desiqnate (if high activity indicated).
After completing sampler, note time and depart from area immediately.
When in a low background area obtain a contact dose rate of sample.
3.15 While transporting the sample assembly, keep it at arms length or use a mobile piq.
This will reduce exposure from the sample as much as possible.
3.16 For ALARA purposes label the sample with the date, time and location of the air sample in a low dose rate area.
For the Marinelli include the initial vacuum level on the label.
It may be necessary to re-bag the Marinelli assembly if used, and tac the sampler assembly since radiation emanating from the sample will not be distinguishable from possible external contamination (exterior of beaker may be smeared to confirm).
86 *H5'-@C-3 3.17 Return to the Control Point or other area as directed by the RPC and turn in the sample to the Radiation Materials Coordinator / designate.
4.
References 1.
Hope Creek Generating Station Emergency Plan, Section 3 (Qrganization).
2.
Salem Generating Station Emergency Plan Procedures, Volume II,Section IV, Radiation Protection Emeroency Procedure, EP IV-112.
5.
Signature Page 6.
Attachments 1.
Diagram of Sampler Assembly 2.
Marinelli Air Sample Analysis Worksheet 3.
Iodine Air Sample Analysis Worksheet HCGS Rev. 2
PAGE 3
~
EP IV-ll2 Pg. 2 of 9 3.2 Assemble a team comprised of in-plant radiation monitoring technicians and designate a team leader.
(Two person entries shall be the minimum used.)
Clearly define the purpose, location and the appro-priate hold points for the team.
Physical hazards (steam, water, etc.) as well as radiological hazards which may be encountered by the sampling team should be discussed.
3.3 Ensure that the team members have the proper clothing, dosimetry, and equipment desianated on the RWP/ERNP.
Self-contained breathing apparatus (SCBA) may be worn as a precautionary measure.
THE SAMPLING TEAM LEADER SHALL:
3.4 Ensure that the team members are properly briefed, eculpped and are familiar with the areas to be entered and this samplina procedure.
3.5 Inform the team of a route, as practical, which minimizes the radiation exposure to the team members.
Track the dose to the team members and observe the appropriate abort points.
3.6 Instruct team to periodically check their dosimetry.
3.7 Ensure that contamination control is maintained to the degree possible under the circumstances.
3.8 At the conclusion of the mission, proceed with personnel and equipment decontamination, as necessary.
3.9 Ensure that the results of the sampling are properly documented and the team is debriefed at the conclu-sion of the mission.
Provide a briefing to the RPC.
THE TEAM MEMBERS SHALL:
3.10 Obtain a briefing from the RPC concerning the type of samples to be taken.
84-4r-106 - 9 3.11 ror iodine and/or noble gas determination obtain key l
from Control Point for locker at 137' elevation.
Obtain a Marinelli beaker (See Attachment 1).
If no beakers are available go to CR/OSC emergency locker.
Use Attachment 2 for loqqing data.
HCGS Rev. 2,
+4 PAGE 4 EP IV-112 Po. 3 of 9 84-- 4 0-10 C - 4 3.11.1 Use only a Marinelli beaker which has 20" Hg or more of vacuum pressure.
EPIV-113 provides correction table for values less than 30" Ho.
3.11.2 For beakers less than 20" Ha or to'incre'ase pressure obtain a vacuum pump f rom 124'
{
elevation, instrument issue room.
Disconnect j
filter holder assembly from stopcock.
Attach
~
vacuum pump'to stopcock opposite vacuum cauge (Attachment 1).
Start pump and evacuate Marinelli between 20" and 30" Hg.
Close i
stopcock before shutting pump or removing hose.
3.11.3 obtain'from 137' elevation locker a samplina head.
Check for Radeco filter /cartridae j
holder, particulate filter paper and silver zeolite cartridge, and connect this assembly to the valve of the above Marinelli beaker.
Note: The entire assembly may already be pre-assembled. Check 0-rinas of the Radeco holder and carefully clean them, if necessary, to ensure an air-tight seal.
3.11.4 Attach the sampling head to the fiarinelli beaker and hand tighten to ensure an air-tight fit.
The airtight integrity of this sampling system is critical due to the small size of the air sample to be obtained.
A small air leak could completely invalidate the results of the sampling leading to subsequent unnecessary exposures or over-exposure to workers.
k l
3.11.5 Bag the sampler assembly leaving only the fil-ter holder exposed to prevent contamination of the outside of the Marinelli beaker (which I
could cross contaminate the H.P.Ge detector during analysis.)
i 3.12 For only iodine determination, use a low volume air sampler with battery pack (H-809 B2).
Both are obtained at 137' locker, 124' CR/OSC locker, and at i
TSC.
Check charge on battery pack by turning it on.
If it is not charced obtain another from above locations or 124' instrument issue room.
Use for logaina data.
i I
Rev. 2 j
HCGS t
s PAGE 5 EP IV-ll2 l
Pace 8 of 9 8 %-H T-10 L. - 1 ATTACRMENT 2 l
l MARINELLI AIR SAMPLE ANALYSIS AIR SAMPLE NUMBER RWP NUMBER,,
LOCATION General Area Dose Rate mR/hr DATE/ TIME TYPE OF ANALYSIS (NG and/or I)
INDIVIDUAL SAMPLING INDIVIDUAL ANALYZING VOLUME CORRECTION (or use Attachment 3, EP IV-113)
- 1. Initial Vacuum Pressure (Pa):
9500 x Pa/30.0 Pa = actual cauce pressure
- 2. Ve (cc)
=
in inches V
= 9500 x
/30.0 c
(cc)
V - =
e Noble Gas (Marinelli)
Iodine (Filter /Cartridae)
Germanium Spec. Analysis Germanium Spec. Analysis l
attached Y N
attached Y N
If yes, Dose Rate at d.etector If yes, Dose Rate at detector face is mr/h r is mr/h r If no mr/h r If no:
1.
D.R.
(1 ft)
=
mr/hr (time) 1.
D.R.
(1 ft)
=
(400)
D.R. (mr/hr)
(time)
- 2. A (uCi)
=
uCi D.R. =
A = 400 (
)
- 2. A (uCi/cc)
=
=
or or mr/hr 1.
D.R.
(2 ft) 1.
D.D.
(2 ft)
=
=
(time)
(time)
(1600)
D.R. mr/hr (4.0) (D.R.)
- 2. A (uci)
- 2. A (uct/cc)
=
=
uCi A = 1600 (
)
uCi/cc
= (4.0) (
)
=
=
Activity Concentration I-131 A.C. = (
)
uCi/ (
) cc =
uC1/cc Instrument Used:
Instrument Used:
Serial Number:
Serial Numbers Cal. Due Dates Cal. Due Date:
11 CGS Rev. 2
PAGE 6 8 G - w -I ce - 4 ATDOMINT 3 EP IV-ll2 Po. 9 of 9 AIR SAMPfE ANALYSIS MNtK SIEET Sampled from:
Date/ Time Collected 7bchnician Sample Type Stcrt Time Stop Time Flow Rate 7btal Voltzne 5 min. Bkad.
Ba-133 Count (cm)
(ccm)
Dat2 of Source Ba-133 Activity Decay Correction Valve (D.C.V.)
(uCi)
(Attach. 4 EP IV-ll3)
Analyzer Used Serial or Channel 4 Counter Efficiency Cal. Due Date Geonetry Used cpn/ dan WLLME Iow Voltrne Sanpler Marinelli Sample Sample Time
- Flcw Rate
- 2.832E4 = Tbtal Voltsne Corrected volume = 9500
- Pa/30 Where Pa is actual pressure mins * (2.832E4) * (
) cfm =
cc (or use Attachnent 3)
Vc(cc) = 9500 *
/30 =
cc Ba-133 cpn
- 1.2 can (from EPIV-113 Eff. (cpn/dgn)
=
=
uCi *
(D.C.V.)*2.2E6 dan step 9-h)
(Corrected can - background) *
- 4. 5E -7 uCi Activity (uCi)
=
=
cc Eff. (cpn/dpn)
Vc (cc) of Iodine t
Totsl Airborne Radioactivity concentration (uci/cc)
Technician Date/ Time Analyzed Rad. Prot. Supv./ Shift IN Date HCCS Rev. 2 r
c.
__.__..y
PAGE 7 EP IV-ll2 Pg. 4 of 9 3.12.1 Place the iodine cartridge and a filter paper into the filter holder with the filter paper in front of the cartridge facing the environ-ment.
3.12.2 Mark with an arrow the direction of air flow throuch the iodine cartridge.
Attach the fil-ter housino to the sampler.
llr-9f-10C -6~3.13 The team should be briefed by ALARA Review Coordinator or the Senior Radiation Protection Technician as to what the hold points are (Ref.
EPIV-104.3.10).
The team shall proceed to the desianated sampling location, continously monitorina the dose rates and periodically checking their dosimeters.
If a hold or abort point is reached, (determined by ALARA Review Coordinat'or or Senior Radiation Protection Technician) return immediately to the Control Point and notify the RPC of the reason i
for the abort.
3.14 When the designated sampling location is reached, perform a radiation survey and document the readings i
on Attachment 2.
3.14.1 For the Marinelli assembly, check the readina of the vacuum gauge level and record on side of beaker in Ha, and on Attachment 2.
Slowly open the Marinelli beaker valve to which the Radeco holder is attached.
This will draw a maximum sample volume of 9500 cc through the l
filter and cartridae and provide a noble cas in the beaker as well.
A slight hiss should l
be heard if the ambient noise levels are not excessive.
After the vacuum gauce has returned to 0 inches of vacuum, close the valve, note the time and depart from the area immediately.
HCGS Rev. 2
PAGE 8 EP IV-ll3 Pg. 3 of 18 3.10 Continue monitoring background radiation le~vels for marked increases.
3.11 Continue to monitor your exposure.
Using pocket dosimeters and calculations, continue updating ex-posure status.
If doses exceed or are likely to exceed previously determined limits, contact the Radiation Protection Coordinator at the Control Point.
3.12 Analyze an emergency grab air sample (obtained using EP IV-112.)
3.12.1 Separate the filter / cartridge from the Marinelli beaker or air sampler, as used, by unscrewing the top off the Radeco cartridge holder and removing the filter and cartridge.
Double bag the Marinelli, if used, and the filter / cartridge.
Label each sample accordingly.
3 k-4 f" lO C - b 3.12.2 For iodine determination, temporarily place the Marinelli beaker, if used, in a place that will facilitate exposure reduction and not interfere with the measurement in progress, and purge the cartridge for one minute using the portable nitrogen supply.
Although the residual effluent from the cartridge contains essentially negligable noble gases, ensure that the effluent is properly vented.
3.12.3 Iodine concentration determination a.
If the count room's background is low (1 0.5 mR/hr) determine sample exposure rate using an RO2 or RO2A (obtained from instrument issue room).
Close the window of the instrument and hold the bottom of the detector one inch from the sample cartridge (See Attachment 1).
Insure that cartridge has arrows down (inlet side up).
4 Rev. 2 HCGS
-,y-v
_--._--_.y-
PAGE 9 EP IV-ll3' Pg. 4 of 18 4
~
1 If the sample exposure rate is less than
$ 6 - 4 h~ - 1 0 C, - 8 0 3mR/hr sample may be counted using H.P.
Ge spectrometry system in accordance with RP-SA.ZZ-002(Q) 5.2, Iodine Air Sample Analysis.(3 mR/hr based on ref. 4).
If the sample exposure rate is greater than'3 mR/hr use the rule of thumb calculation to determine iodine concentration (3 mR/hr based on ref. 4).
b.
If counting room is in high background for counting (> 0.5 mR/hr) determine sample exposure rate using an RO2 or RO2A.
Close the window of the instrument and hold the bottom of the detector case one inch from the sample cartridge (See Attachment 1).
Insure that cartridge has arrows down (inlet side up).
f b - 4 f-10 C - 7
- If the sample exposure rate is less than 3 mR/hr take the sample to a low background (< 0.5mR/hr) area and perform the analysis using a SAM-2 with an RD22 probe in accordance with Attachment 2 (3 mR/hr based on ref. 4).
- If the sample exposure rate is greater than 3 mR/hr use the following rule of i
thumb calculation to determine iodine concentration (3 mR/hr based on ref. 4).
3.12.4 Perform the rule of thumb procedure for iodine i
concentration determination, as follows.
Place the cartridge in any convenient a.
location in the counting room, such as on a table.
3 b - 4 7 -- l C C, - fl b.
Put the RO2 or RO2A, closed window, one foot from the front and center of the cartridge (inlet side up, see Attachment 1).
I i
Re v. 2 I
HCGS I,
i
PAGE 10 16 -9 5-- lo c. - 9 EP IV-ll3 Pg. 10 of 18 ATTACHMENT 1 SOURCE PLACEMENT RO2/RO2A Window Closed R02A
,/
/4 1 Inch Inlet Side c-
%f
[
f Cartridge (Arrows Indicate Air Flow)
RD19/RD22 With Cartridge r
k
[
Arrows With Disc Source Indicate f
i Air Flow Ba-133 Inlet Side g7, ff j gp Source RD22 RD22 Probe Probe Rev. 2 HCGS
~
PAGE 11 EP IV-113 Pg. 13 of 18 h)
If instructed to do so by the RPC, calculate the efficiency of the instrument following steps below.
Otherwise record the efficiency from the instrument on and proceed to 9.i.
.)k-ST-10 L-Q 1 )
Obtain Ba-133 source f rom Control Point Locker at 137' elevation or count room and place on the detectoc in the center (See Attachment 1).
Press reset - start sutton for one minute count.
Note count rate in cpm on.
2)
Note posted activity on Ba-133 (uCi) source label and the decay correction factor on Attachment 6.
3)
Determine the ef ficiency using the following equation (on ).
Eff. (cpm /dpm) = cpm Ba-133
- 1.2 (Energy Correction Factor) uCi(Ba-133 Activity)
Decay Correction Factor *2.2E6 Decay correction f actor f rom Attachment 4.
4)
Remove the Ba-133 source and note the efficiency on.
NOTE 1.2 is a correction factor to allow for the difference in energy abundancies between Ba-133 and I-131.
i.
Count background for 5 minutes (set count time to 5 and X1) and record this value on Attachment 6.
Total background counts divided by five minutes is background ccpm.
j.
Determine the corrected volume sampled using Attachment 4 and record on Attachment 6.
HCGS Rev. 2
~,
PAGE 12 EP IV-ll3 Pg. 2 of 18 NOTS Normally, the Chemistry Counting Room would be designated the " hot" lab.
3.4 Determine amount of samples awaiting analysis and consider establishing relative priorities for each before the backlog becomes excessive.
Samples and data for evaluating Protective Action Guides should receive the highest priority.
3.5 Inform the inplant monitoring technician where to deliver samples.
3.6 Ensure that the designated counting room is prepared prior to sample arrival and counting room personnel have the proper clothing and dosimetry as designated on the RWP.
NOTE:
THE MINIMUM PROTECTIVE CLOTHING SHALL CONSIST OF LAB COAT AND EITHER ONE PAIR OF RUBBER OR TWO PAIRS OF LATEX (SURGEON's) GLOVES, AND PERSONAL DOSIMETRY.
The following equipment shall be available in the counting room.
a.
HP Ge spectrometry system b.
SAM-2 dual channel analyzer with an RD 22 probe.
c.
Survey meter with a closed window (photon detec-tion) readout in mR/hr and a range allowing readings to the nearest 0.5'mR/hr.
(An instrument such as the RO2 or E-520 is appropriate.)
THE COUNTING ROOM PERSONNEL SHALL:
3.7 Perform contamination surveys before taking the sample into the counting room.
S b- %~-100-lI3. 8 Survey the sample and store in lead pigs, if available, or sample vault.
Locate sample as f ar away from personnel as possible for exposure reduction.
3.9 Handle all samples with tongs or tweezers, if applicable.
HCGS Rev. 2
r PAGE 13 EP IV-ll3 Pg. 14 of 18 k.
To determine activity concentration place Saran wrapped sample on detector face and take 5 minute count.
Divide count rate by 5, subtract background and use in equation (on Attachment 6):
(Corrected cpm - backaround)* 4.5E-7 Activity Concentration (uCi/cc)
=
Corrected Volume (cc)
Eff. (cpm /dpm)
(L -- 4 f-ID L - Is' l.
Carefully mark and save all samples for later laboratory evaluation.
Wrap samples in clean Saran wrap or equivalent (e.g., surgical gloves) for storage.
If sample is to be saved refer to EPIV-lll and Radiation Material Coordinator / designate.
Sample must be identified as radioactive material.
l l
l l
I HCGS Rev. 2 i
l
.