ML20234B240

Ack Receipt of Providing Notification of Discrepancies Identified in pre-1987 Personnel Radiation Dose Assessment & Reporting Programs.Written Summary of Activities Re Ongoing Review of Records Requested

ML20234B240
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/14/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8709180326
Download: ML20234B240 (2)

Text

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SEP l 41987 In Reply Refer To:

Dockets: 50-313 ,

50-368 I l

Arkansas Power & Light Co:npany ATTN: Mr. Gene Campbell Vice President, Nuclear Operations P. O. Box 551 Little Rock, Arkansas 72203

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Gentlemen:

Thank you for your letter of July 30, 1987, providing notification of the discrepancies you identified in your pre-1987 personnel radiation dose assessment and reporting programs. We find your commitment to review all historical exposure records (approximately 50,000) and correct selected records to be satisfactory considering the magnitude of the project. We also understand that your preliminary findings indicate that you do not expect your review and assessment of past personnel exposures, involving extremities and the whole body, to result in any identification of personnel exceeding 10 CFR Part 20 radiation exposure limits. Based on a telephone conversation with your Mrs. P. Michalk on September 1,1987, it is requested that you provide clarification as to what you will consider to be an exposure that " adversely affects a person's cumulative whole body exposure."

We request that you provide this office with a written summary of activities involving this ongoing review of records on a semiannual basis until the project is finished. The first summary should include the clarification requested above. A final comprehensive report of your findings and your corrective actions shall also be provided to this office.

We have no further questions at this time on your proposed actions.

Sincerely, ORIGINAL SIGNED BY:

J. E. Gagliardo, Chief Reactor Projects Branch cc:

J. M. Levine, Director Site Nuclear Operctions Arkansas Nuclear One P. O. Box 608 Russellville, Arkansas 72801 Arkansas Radiation Control Program Directer bcc: (see next page)

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RPB Resident Inspector R. D. Martin, RA RPSB Section Chief (RPB/B)

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July 30, 1987 -

OCEN078717 Mr. Larry A. Yandell Chief, Radiological Protection and Safeguards Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

SUBJECT:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License No. DPR-51 and NPF-6 Personnel Occupational Exposure

_ Data Discrepancies

Dear Mr. Yandell:

As committed in a phone conference of July 24, 1987, with Mr. Dean Chaney of your staff, information is provided concerning discrepancies in personnel occupational exposure records as described in the attached report. l We are currently working towards correcting the records by the end of 1988. This effort includes approximately 50,000 records for an estimated 8000 individuals. The discrepancies are, for the most  !

part, record-keeping errors and do not warrant expending considerable 1 resources to accelerate completion of the effort. Mr. Chaney agreed with this approach.

I We do not, at this time, propose to submit corrected reports relating to quarterly limits. In instances shere cumulative whole body doses are adversely affected, however, corrected reports will be submitted to the individual ano to the NRC.

We will continue to keep you informed of the progress of this effort.

. incerely,) ,

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b i Dosimetry Records for Occupational Exposure ]

l During our recent improvements in personnel exposure tracking which included installation of a computer system, a review of historical q dose records was performed in conjunction with the transfer of )

records to the computer database. In the course of this review, several discrepancies were identified which resulted in the possibility that reports filed under 10CFR19.13, 10CFR20.408, and  !

10CFR20.409 were incorrect and that reports required under j 10CFR20.405 were not filed. j The discrepancies involved inconsistencies in the summary of extremity doses, incorrect recording and calculation of extremity doses, failure to record skin of whole body doses, and inconsistencies in reporting exposures to the head in relation to I the whole body dose. The discrepancies occurrad in varying degrees I over a period of approximately ten years. Details of the i discrepancies are provided below.

I. Exposures Relating to Quarterly Limits A. Extremity Dose Summaries Between 1973 and 1983, doses to the extremities were summarized and reported inconsistently on the NRC Form 5, Current Occupational External Radiation Exposure reports.

• Hands and feet doses summed and reported as extremity

• Hands and feet doses reported separately as extremity

• Higher of hands and feet doses reported as extremity

• Hands and feet doses added to whole body dose

• Hands and feet doses reported completely separate from whole body dose The records will be corrected from the exposure data.

There have been no extremity doses that have approached ,

quarterly limits; therefore, correction of these I inconsistencies should not result in persoiinel l overexposure during any quarter of the ten year period.

B. Depth of Extremity Doses l Between June 1973 and October 1986, ANO has used Harshaw TLD chips in two different types of holders. Both types .

I of holders employed two chips, one at a depth equivalent in body tissue of 32 mg for shallow dose measurement and ,

one at a depth of 285 mg for deep dose measurement. The 1

( 285 mg chip satisfies the 300 mg oc less requirement of i j the NRC Form 5. The 32 mg chip, although not strictly )

l satisfying the 7 mg or less requirement, does compare  !

favorably with industry standards of this time period.

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l From 1973 to 1983, AN0 recorded and reported extremity i doses, in most cases, using the deep dose value instead of the shallow dose value as required by NRC Form 5 instructions.

Therefore, the extremity dose was reported at the wrong depth. Individuals here during this period of time who have tereinated employment were sent termination letters with this dose reported inconsistent with the instructions on NRC Form 5. Copies of the letters mere sent to the NRC as well.

l Our records will be corrected from exposure data to the extent l possible. These corrections relate to quarterly limits and i will not affect an individual's accumulated whole body. l dose.

C. Skin of Whole Body Doses In 1973, skin of whole body doses were reported as part of the whole body dose on NRC Form 5. This was conservative and, in effect, means that the whole body dose limits, which are lower, were applied during this period to the i skin of whole body. However, from May 1977 to February 1 1981, skin of whole body doses were not added to the whole q body dose reported on NRC Form 5, nor were these reported correctly to individuals in termination letters. For this ]

four year period, even though the doses were not reported j on Form 5, they were recorded and the data is available to '

correct the records.

II. Exposures Relating to Accumulated Whole Body Doses The discrepancies identified in this area relate to the reporting i of head doses. A whole body TLD was issued to an individual for a period of time. In some instances within this period of time, a head TLD was also issued. The higher of the two doses was generally reported as the whole body dose for the period. If the period of time che heaJ TLD was issued covered the entire period that the whole body TLD was issued, the reporting method was acceptable. However, if ttie periods did not coincide for  ;

the entirety, the reporting method was inappropriate. Depending  :

on how the total dose is corrected, and this has yet to be determined, an individual's cumulative whole body dose is i subjecttoincrease. In such cases, revised forms will be j issued.

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