ML20207N149
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| ML20207N149 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/06/1987 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil Public Service Enterprise Group |
| References | |
| NUDOCS 8701140017 | |
| Download: ML20207N149 (2) | |
See also: IR 05000354/1986045
Text
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JAN 0 61987
Docket No. 50-354
Public Service Electric & Gas Company
ATTN: Mr. C. A. McNeill, Jr.
Vice President - Nuclear
Post Office Box 236
Hancocks Bridge, New Jersey 08038
Gentlemen:
Subject: Inspection 50-354/86-45
This refers to your letter dated December 18, 1986 in response to our letter
' dated November 18, 1986.
Thank you for informing us of the corrective and preventive actions documented
in your letter. These actions will be examined during a future inspection of
your licensed program.
Your cooperation with us is appreciated.
Sincerely,
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M L Co.E.
051AlidiSikEc~db h][[cv m f
,[gomas T. Martin,
Division of Radiation Direct'or
Safety and
Safeguards
cc:
R. S. Salvesen, General Manager, Hope Creek Operations
A. E. Giardino, Manager, Station Quality Assurance
W. H. Hirst, Manager, Joint Generation Projects Department, Atlantic
Electric Company
L. A. Reiter, General Manager - Licensing and Reliability
Rebecca A. Green, Bureau of Radiation Protection
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
,
State of New Jersey
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8701140017 870106
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OFFICIAL RECORD COPY RL HC 86-45 - 0001.0.0
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Management Assistant, DRMA (w/o enc 1)
DRP Section Chief
Robert J. Bores, DRSS
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Putt c Service
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CorDin A. McNeill. Jr. Put,ic Service Eiectnc anc Gas Comoany P O Box 23E.Mancocks Bndge N,:0B038 609 339 4800
See 5 es :e-:
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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 bection 10.0 of tne
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
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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
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. 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(O).
OPEN ITEM 50-354/86-45-02
-
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
charcoal 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 fur 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 s.7mpling procedure does not specify whether to use
the air sarapler rotameter or the flow maintained by the
limiting flow orifice in calculating airborne particulate
and iodine activity.
t
Chemistry uses the air sampler rotameter in accordance with
Procedure CH-EO.SH-001(O), 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.
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. c. The PASS sampling procedure requires that an airborne
particulate and iodine 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 setpoint 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(O) has been revised
to call for samole 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
RI+DONSE
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 "AS-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 ce 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.ZZ-Oll(0)).
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. RESPONSE
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a. Revisions have been made to CH-EO.SH-004(0), 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-011(0) 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(0) 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
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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
labora to ry . 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 tne design
criteria.
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c. Tho tongs used for removing the containment gas esmple 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
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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
detectors as they approach maximum concentration of 105
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
channels) have been calibrated in accordance with the
vendor's methodology utilizing NBS 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 l
the stated 105 uci/cc channel range. This testing will be
used to verify gaseous officiencies, 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 camma and beta disc sources
to verify detector energy response. In addition, the
linearity of each channel has been tested in excess of 105
CPM using solid Sr-90 disc sources.
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To implement a nsw sito temporcry
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procedure RP-TE.SP-012(Q) tacting,itten
be wr prior to December
31, 1986. This procedure will be reviewed by site Radiation
Protection staf f 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
activities must be scheduled within the restraints of plant
operation. 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, these testing activities are expected to
be completed by March 31, 1987.
e. The inspectors suggested that PSE&G consider regular
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(0) will be revised by January 31,
1987 to require verification of all Tech Spec related
satpoints at least weekly, ar.d 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 vent sample collection procedure RP-TI.SP-003(Q) 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.
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Note: The procedure was incorrectly referenced as
(RP)ST-003(0) in the inspection report. !
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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(0) 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-T1.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
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Containment High Range Monitor improvement items
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RESPONSE
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a. The inspector noted that the Containment High Range Monitor
was not described in alarm response procedures.
Procedure OP-AR.ZZ-Oll(0) is being revised to address this
concern. The estimated issue date of this procedure
revision is January 31, 1987.
b. The monitor surveillance procedure (IP-CC.SP-041(0)) does
not verify alarm annunication (signal transfer from the
RM-80 to the RM-ll),
This procedure will be 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 electrical connectors.
Further study has revealed that Conax Corpcration 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 cenfiguration. A safety
evaluation performed by PSE&G Engineering has esablished the
similarity between the tested configuration and the Hope
Creek configuration. This safety 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-a tubing is to be replaced (assuming
maximum temperature conditions prevail throughout the entire
22 years of use).
OPEN ITEM 50-354/86-45-10
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Improvement items for In-Plant Iodine Instrumentation Under
Accident Conditions
RESPONSE
a. The inspector requested that the acceptability of the
methods used by PSE&G to determine the efficiency of SAM-2
single channel analyzer be evaluated or that the method be
changed to provide a geometry which is more consistent with
the iodine deposition to be expected (i.e. face loaded,
uniform iodine deposition).
A face loaded uniform " calibration" zeolite cartridge has
been ordered from our vendor which will alleviate potential
geometry problems associated with the counting of these
samples. The anticipated delivery date is Janaury 15, 1987.
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.. b. Tho insosctor suggested that "hanos on* training with
, emergency sampling equipment be provided as opposed to the
current practice of procedure walk throughs with some hands
oon 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-ll2 and EP-IV-113).
The following changes were made to these procedures in
response to the inspectors comments. The affected pages are
attached (see Attachment B):
1) The locations for sample 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, Page 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
designee. (See Step 3.14.2, Page 2 of. Attachment B).
3) The sample " turnover" requirement to ensure the
Radiation Materials Coordinator receives samples is to
turn in the sample to the RMC or his designee directly.
(See Step 3.17, Page 2 of Attachment B).
4) The sample documentation requirements are clarified and
described by reference to the proper' attachments for a
Marinelli air sample and an air sample analysis work
sheet. (See Step 3.11 and 3.11.1 and referenced
attachments, Pages 3-6 of Attachmenmt 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 preceding steps of that
procedure. (See Step 3.13, Page 7 of Attachment B).
6) The nitrogen purge location for purging sample
cartridges is in a place that will facilitate exposure
reduction and not interfere with the measurements in
progress (See Step 3.12.2, Page 8 of Attachment B).
7) The terms " habitable / accessible" were defined as low
background areas (< 0.5 mR/hr.).
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, 8) The maximum allowable background to count / analyze sample
cartridges is defir.ed 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 C.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 airborne
activity when using the SAM-2 was established and is
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included in the procedure. (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 inches
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 side down (arrows
pointing up) and is diagramed. (See Step 91, Page 10
and 12 of Attachment B).
15) Acceptable samole storage locations are described and
referenced in EP IV-lll as the sample storage cave and
or a lead pig (See Steps 3.8 and 4.1, Page 13 and 14 of
Attachment B).
d. Procedure RP-SA.ZZ-002(O), Airborne Radioactivity Analysis
was missing from the controlled procedures in the Hope Creek
Technical Support Center (TSC).
The set of controlled Radiation Protection procedures
located in the main TSC area is not a complete set. This
set includes selected procedures which may provide guidance
to Radiation Protection personnel assigned to the TSC.
Maintenance of a controlled copy of the Airborne
Radioactivity Analysis procedure within the TSC is neither
appropriate nor necessary. However, it should be noted that
two (2) complete controlled sets of Radiation Protection
procedures are located in the upper level of the TSC (Hope
Creek Radiation Protection office area) for use, if needed.
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, e. The inspector noted that Procedure RP-TI.ZZ-031(O) is
referenced in Emergency Procedures but that this procedure
has not been formally established 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 dedication of additional SAM-2s
in the emergency lockers of the Hope Creek Emergency
Response Facilities.
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 available
at the instrument issue room on the 124' elevation.
OPEN ITEM 50-354/86-45-11
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OA and Design Review improvement items
RESPONSE
a. Applicable procedures did not address actions required to
ensure the availability of the elevator which is used to
transport the PASS sample to the chemistry laboratory.
Emergency Procedure EP IV-204 has been revised to state that
the Chemistry Activities Coordinator shall be responsible
for notifying the Control Room to energize elevator 31-04
via motor contol center MCC-00B474. Procedure
CH-EQ.SH-007(O) (for transporting the PASS sample) will be
revised by January 31, 1987 to include a precaution that the
Chemistry Activities Coordinator ensure that elevator 31-04
is appropriately energized prior to transportation of the
PASS sample.
b. The PASS Operation and Maintenance Instruction Manual dated
November 1981 did not reflect as-built design changes which
have been prescribed by the manuf acturer (General Electric)
and incorporated into the system.
PSE&G has discussed this with the manuf acturer. General
Electric is to provide an updated manual which incorporates
all of the aforementioned changes / revisions by December 31,
1986.
c. The inspector requested clarification of the calibration
rEqdirements for PASS panel instrumentation.
Hope Creek FSAR Section 9.3.2.3.2, item J.6 states that
" equipment used for post accident sampling analysis will be
calibrated or tested approximately every six months." In
keeping with this commitment, test sampling is performed
every six months by the Chemistry department to determine
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the cccurecy of the cquipmont. If problems are encounterod,
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appropriate instrumentation will be recalibrated at that
time. Othe rwise , those instruments which are necessary for
PASS sampling are calibrated every 18 months.
d. The inspector suggested that an-adaptor be developed to
facilitate the operation of PASS panel control switch
HC-652.
An adaptor to provide the additional leverage required to
facilitate the rotation and holding of control switch HC-652
will be incorporated into the PASS panel in accordance with
Design Change Request (DCR) 4-HME-86-1326. This DCR is
projected for completion in the first quarter of 1987.
OTHER COMMITMENTS
PSE&G made several other performance related commitments
during the course of the inspection. The commitments made
and related responses 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 Directive CH-DD.ZZ-018 was written and implemented
on September 29, 1986.
b. PSE&G committed to revise the PASS procedure by September
29, 1986 to provide clear guidance for dissolved gas
sampling.
Procedure CH-EO.SH-001(0), 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 problems identified by NRC
during observation of dissolved gas sampling.
c. PSE&G committed to qualifying at least one Chemistry
Technician or Chemistry Assistant per shift in the revised
PASS procedures 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 procedures by October 10, 1986.
Prior to startup subsequent to the end of the inspection, at
least one Chemistry Technician or Chemistry Assistant was
qualified. All Chemistry Technicians and Chemistry
Assistants were qualified on PASS by November 26, 1986. The
October 10, 1986 date was not met because of testing
restrictions on equipment imposed by the Hope Creek Power
Ascension program.
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d. PSE&G committed to comploting Salf Contcinsd Br@cthing
, 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. PSESG committed to providing " hands-on" training in use of
the in-plant iodine 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.
-
_ _ - _ .
_
_
. ATTACHMENT B PAGE 1
-
EP IV-112
-
Pa. 3 of 9
)( 15'-100 -13 3.11.1 Use only a Marinelli beaker which has 20" Mc
or more of vacuum pressure. EPIV-113
Attachment 3 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 from 124' ;
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" Ha. Close
stopcock before shutting pump or removing
hose.
3.11.3 Obtain from 137' elevation locker a samplina
head. Check for Radeco filter /cartridce l
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 O-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 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
durino analysis.)
lG-- 9f-lC L -l 3.12 For only iodine determination, use a low volume air f v - 9 7 - 10 F sampler with battery pack (H-809 B2). Both are
obtained at 137' locker, 124' CR/OSC locker, and at
TSC. Check charge on bettery pack by turning it on.
If it is not charged obtain another from above
locations or 124' instrument issue room. Use
Attachment 3 for logaina data.
MCGS Rev. 2
-- e-s
,
'
PAGE 2
*
EP IV-ll2
,
Pg. 5 of 9
S(o-- W- ioc ') 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 neriod 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 lenath or use a mobile pic. 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 tag 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).
8b -45 106-3 3.17 Return to the Control Point or other area as directed
by the RPC and turn in the sa.mple to the Radiation
Materials Coordinator / designate.
4. References
1. Hone Creek Generating Station Emergency Plan, Section 3
( 0.rq a n i z a t ion ) .
2. Salem Generating Station Emergency Plan Procedures,
Volume II, Section IV, Radiation Protection Emercency
Procedure, EP IV-ll2.
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
4
-- , , _ . - - . . - , .,. - , . , . - . , . - - . , , - - - . -. - - . _ ,
--..- - - - -
,
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PAGE 3
.
.
EP IV-ll2
Pg. 2 of 9
3.2 Assemble a team comprised of in-plant radiation
monitorina technicians and designate a team leader.
(Two person entries shall be the minimum used.)
Clearly define the purpose, location and the aporo-
priate hold points for the team. Physical hazards
(steam, water, etc.) as well as radiological hazards
which may be encountered by the samplina team should
be discussed.
3.3 Ensure that the team members have the proper
clothing, dosimetry, and equipment desianated on the
RWP/ERWP. Self-contained breathing aonaratus (SCBA)
may be worn as a precautionary measure.
. THE SAMPLING TEAM LEADER SHALL:
3.4 Ensure that the team members are properly briefed,
ecuipped 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 eauipment decontamination, as
necessary.
3.9 Ensure that the results of the samplina are proper 1v
documented and the team is debriefed at the conclu-
sion of the mission. Provide a briefina to the RPC.
THE TEAM MEMBERS SHALL:
3.10 Obtain a briefing from the RPC cor.cerning the tyne of
samples to be taken.
8b-Hr- 106 - 4 3.11 ror iodine and/or noble cas determination obtain key
from Control Point for locker at 137' elevation.
Obtain a Marinelli beaker (See Attachment 1) . IE no l
heakers are available go to CR/OSC emergency locker.
Use Attachment 2 for locoinq data.
MCGS Rev. 2
- _ - _ _ - . -- . , . - _
-
.
PAGE 4
.
'
EP IV-112
Pa. 3 of 9
$4 - Ni'-10 C - 4 3.11.1 Use only a Marinelli beaker which has 20" Ha
or more of vacuum pressure. F.PIV-113
At tac hmen t 3 provides correction table for
values less than 30" Ha.
3.11.2 For beakers less than 20" Ha or to incre'ase
pressure obtain a vacuum pump from 124'
elevation, in s t rument issue room. Disconnect
filter holder assembly from stopcock. Attach
vacuun pump'to stopcock opposite vacuum cauce
(Attachment 1). Start pump and evacuate
Marinelli between 20" and 30" Ho. Close
stopcock before shutting pump or removing
hose.
3.11.3 Obtain from 137' elevation locker a samolina
head. Check for Radeco filter /cartridae ;
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-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 Marinelli
beaker and hand tighten to ensure an air-tight
fit. The airticht intearity 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.)
3.12 For only iodine determination, use a low volume air
sampler with battery pack (H-809 B2). 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 charged obtain another from above
locations or 124' instrument issue room. Use
Attachment 3 for locoinc data.
I Rev. 2
HCGS
.
.
PAGE 5
*
EP IV-li2
Pace 8 of 9
&%-H T- lO l ~ M
ATTACRMENT 2
~
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):
2. V e (cc) = 9500 x Pa/30.0 Pa = actual cauce pressure
in inches
Ve = 950r x /30.0
V e- = (cc) ,
Noble Gas (Marinelli) Iodine (Filter /Cartridae)
Germanium Spec. Analysis Germanium Spec. Analysis
attached Y N attached Y N
If yes, Dose Ra te at d.etector If yes, Dose Rate at detector
face is mr/hr is mr/hr
If no:
If no: 1. D.R. (1 ft) = mr/hr
1. D.R. (1 ft) = mr/hr @ (time)
@ (time) 2. A (uci) = (400) D.R. (mr/hr)
2. A (uci/cc) = D.R. = A= 400 ( ) = uCi
or or
1. D.R. (2 ft) = mr/hr 1. D.R. (2 ft) =
@ (time) @ (time)
2. A (uCi/cc) = (4.0) (D.R.) 2. A (uCi) = (1600) D.R. mr/hr
uCi/cc = (4.0) ( ) = A= 1600 ( ) = uCi
Activity Concentration I-131
A.C. = ( ) uCi/ ( ) cc =
uCi/cc
Instrument Used: Instrument Used:
Serial Number: Serial Number:
Cal. Due Date: Cal. nue Date:
HCGS Rev. 2
.. . . - . . - - -
.
' -
PAGE 6
8 D W-Ice - 4 ATDOMENT 3 EP IV-ll2
Po. 9 of 9
AIR SAMPM ANALYSIS lORK 91EET
Sanpled from: Date/ Time Collected 7bchnician Samole Tme
Stcrt Time Stop Time Flow Rate 7btal Voltrne 5 min. Bkod. Pa-133 Count (cm)
(ccm)
l
Dats of Source Ba-133 Activity Decay Correction Valve (D.C.V.)
(uCi) (Attach. 4 EP IV-113)
Analyzer Used Serial or Channel # Counter Efficiency Cal. Due Date Gemetry Used
egn/dm
'
v0LtNE
~
tow volume Samoler Marinelli Samole
Sample Time * Flow Rate * 2.832E4 = Tbtal Vohrne Corrected Voltane = 9500 * Pa/30
Where Pa is actual pressure
mins * (2.832E4) *( ) cfm = cc (or use Attac!Tnent 3)
Ve(cc) = 9500 * /30 = cc -
!
.
Ba-133 cm * 1.2
Eff. (cpn/dpm) = = can (from EPIV-ll3
uCi * (D.C.V.)*2.2E6 dm step 9-h)
*
(Corrected cm - background) 4.5E-7 uCi
Activity (uCi) = = cc
*
Eff. (can/ dan) Ve (cc)
of Iodine
I Total Airborne Radioactivity Concentration (uCi/cc) l
Technician Date/ Time Analyzed Rad. Prot. Suw./ Shift TN Date
i ! l HCGS Pev. 2 -
.
" 7 ~ - * ' -
r- -.. - -- , , . _
.
-
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.
? b - 4 $~- J Dc. - 5 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 monitorino
the dose rates and periodically checking their ,
dosimeters. If a hold or abort point is reached,
(determined by ALARA Review Coordinatbr or Senior
Radiation Protection Technician) return immediately
to the Control Point and notify the RPC of the reason ,
for the abort. ,
3.14 When the designated sampling location is reached, ,
perform a radiation survey and document the readings j
on Attachment 2.
I
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 j
Radeco holder is attached. This will draw a '
maximum sample volume of 9500 cc through the l
filter and cartridce and provide a noble cas -
'
in the beaker as well. A slight hiss should
he heard if tlw am5ient noise levels are not
excessive. After the vacuum gauce has !
returned to 0 inches of vacuum, close the I
valve, note the time and deoart from the area
immediately.
1
HCGS Rev. 2
_-
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PAGE 8
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,
EP IV-113
Pg. 3 of 18
3.10 Continue monitoring background radiation levels 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
cartLidge. Double bag the Marinelli, if
,
used, and the filter / cartridge. Label each
*
'
sample accordingly.
For iodine determination, temporarily place
$h-%PIOC-b 3.12.2
'
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
( < 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).
HCGS Re v . 2
- - - __.__-- - _ ..-.-. . . . _ . . , , _ - - - - . . - . - _ - _ _ . - - . - . - . - _ . .
-
..
- PAGE-9
,
EP IV-ll3
Pg. 4 of 18
.
8 ( - 4 h~ 1 0 C, - 10 - If the sample exposure rate is less than
3mR/hr sample may be counted using H.P.
Ge spectrometry system in-accordance with
RP-SA.22-002(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 - ? - 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
thumb calculation to determine iodine
concentration (3 mR/hr based on ref. 4).
3.12.4 Perform the rule of thumb procedure for iodine
concentration determination, as follows.
a. Place the cartridge in any convenient
location in the counting room, such as on
a table.
S b - 4 5 -- l o c. -4 b. Put the RO2 or RO2A, closed window, one foot
from the front and center of the cartridge
(inlet side up, See Attachment 1).
-
Rev. 2
HCGS .
.
.
PAGE 10
'; g (, -4 5'-- 10 6 - 't
-
EP IV-ll3
Pg. 10 of 18
ATTACHMENT 1
SOURCE PLACEMENT
RO2/RO2A
__
Window Closed
R02A
.
./
/4
1 Inch
Inlet Side e--- -
%f
Cartridge
.
[ f (Arrows Indicate Air Flow) .
RD19/RD22
With Cartridge
e -
,
( '
- Arrows
Indicate
With Disc Source
i i Air Flow
Ba- '
Inlet Side
#7////L.p
RD22 RD22
Probe Probe
HCGS Rev. 2
_ . _ _ _ _ _ _ _ . - . . _ . _ , ._. _ _ . _ . _ _ _ . _ . . . _ . . . . _ . _ _ . _ _ ._. -
7
- PAGE 11
.
.
EP IV-ll3
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
Attachment 6 and proceed to 9.i.
b'NI-ICL- O 1) obtain Ba-133 source from Control Point Locker at 137'
elevation or count room and place on the detector, in the
, center (See Attachment 1). Press reset - start button
for one minute count. Note count rate in cpm on
Attachment 6.
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
Attachment 6). .
Eff. (cpm /dpm) = com 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
Attachment 6.
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
cepm.
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
NOTE
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
i
sample into the counting room.
8 4 - %~- 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.
4
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- lCx_ - 1 ~~
3 1. Carefully mark and save all samples for later laboratory
e valuat ion. 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.
.
.
.
HCGS Rev. 2
}}