IR 05000286/1987002

Insp Rept 50-286/87-02 on 870127-29.No Violations Noted. Major Areas Inspected:Dosimetry Staffing & Training, Facilities & Equipment Procedures,Dose Assessment QA & Documentation & Recordkeeping

ML20207T224
Person / Time
Site:	Indian Point
Issue date:	03/18/1987
From:	Cioffi J, Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207T209	List: IR 05000286/1987002 ML20207T208
References
50-286-87-02, 50-286-87-2, NUDOCS 8703230322
Download: ML20207T224 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report-No. -50-286/87-02

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License No. DPR-64l Priority Category C

Licensee: Power Authority of the State of New York P.O.. Box 41 Lycoming, New York 13093 Facility Name: Indian' Point 3 Nuclear Power Plant Inspection At: Buchanan, New York Inspection Conducted: ' January 27-29,'1987 Inspectors: @

S. Sherbini, Radiation Specialist l2!Tb date Facilities Radiation Protection Section k L euuG-J.$1offi,s RadiatiopSpecialist shln

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Facilities Radiation Protection Section-Approved by: h ,

/ M M ifil d M. M. ShanBaky,. Chief @ date 8 Facilities Radiation ProtectTon Section

' Inspection Summary: Inspection on January 27-29,1987 (Report No. 50-286/87-02)

Areas Inspected: A special, announced dosimetry inspection, which included inspection of the dosimetry staffing and training, facilities and equipment procedures, dose assessment quality assurance, and documentation and record-keepin Results: No violations were identified as a result of this inspectio PDR ADOCK 05000286 G PDR

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Details 1.0 Personnel Contacted Licensee Personnel

• M.~ Cass, Assistant to the Resident Manager

• W. Josiger, Resident Manager

• T. Labenski, Radiological Engineer

• J. Perrotta, Radiological and Environmental Services Superintendent .

• D. Quinn, Senior Radiological Engineer

• J. Russell, Superintendent of Power - NYPA/IP3 NRC Personnel

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P. Koltay, Senior Resident Inspector

• R. Barkley, Resident Inspector

• Denotes attendance at the exit intervie .0 Status of Previously Identified Items (Closed) 86-11-01 (Violation)._ Failure to control a high radiation area, resulting in a significant potential for overexposur The licensee's corrective action, as stated at the management meeting at-the NRC Region I office on June 24, 1986, and in a letter dated August 15, 1986, were' reviewed. The licensee's actions appeared complete and sufficient to prevent a recurrence of similar incident .0 Dosimetry Program 3.1 Dosimetry Program Staffing and Training The dosimetry program organization and training was reviewed with respect to program development, implementation, and improvemen Although the inspector found the dosimetry staff to be technically competent, with a good understanding of the dosimetry program and dose assessment. consideration should be given to increasing the number of personnel associated with the dosimetry program implementation to orovide improved oroaram oversight and upgrading. For example,the Phdiol'o gicf

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Engineer in charge of the dosimetry program was principally involved in the daily operation of the technical aspects of the program and did not appear to have sufficient time to devote to such activities as procedure upgrades and improvement, software development and testing, resolution of technical problems, and improvement of quality control charts and criteria for identifying program deficiencie .

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-3 The inspector discussed this concern with licensee management. The licen-see stated ~that additional dosimetry-technicians were planned for the program, and consideration would be given to provide _an additional technical assistant to assist in the routina and non-routine tasks necessary to implement a high quality dosimetry progra This area will be reviewed in a future inspectio The . inspector discussed training of dosimetry department personnel and found the staff to be adequately trained and' retrained for their responsibilitie .2 Facilities and Equipment The licensee uses several personnel dosimetry systems and services. The primary, in-house, system is a Panasonic TLD system. The dosimeter is a four element design, model 806 A All the elenents are lithium (Li-6) borate powder of approx-

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imately 14 milligrams per square centimeter nominal thicknes The dosimeter is mounted inside a water-tight casing or hanger that was designed by the licensee. The filtration over the four elements of the dosimeter, including that contributed by the hanger, is as follows:

Filtration (milligrams per square centimeter)

Element 1 18 (mylar)

Element 2 150 (mylar, plastic)

-Element 3 300 (plastic)

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Element 4 1000 (plastic) _

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The licensee selected this badge and hangar material because the-density of the entire assembly is nearly tissue equivalent. There are no metal parts in the assembled badge other than the clip used to attach the badge to the weare The licensee plans to replace the model 806 AQ dosimeter with the model 812 AQ, which contains neutron insensitive lithium (Li-7)

borate elements and will have slightly less filtration (60-75 mill-igrams per square centimeter) over element 2. Currently, the licen-see uses a Landauer TLD, composed of lithium-7 fluoride phosphor material for containment entries at power, because the 806 badge provides poor resolution in a mixed field of beta and neutron radiatio The licensee uses a Landauer track-etch dosimeter to augment the monitoring of neutron exposures. The licensee had performed some independent evaluations on neutron response of these dosimeters and found that they did not adequately measure neutron exposure to a known neutron source. Therefore, although still used for personnel neutron monitoring, the licensee assigns neutron doses based upon survey instrument measurements and stay time _

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Extremity monitoring is performed with a single element Panasonic finger dosimeter, the model 80 The Panasonic dosimeters are processed on-site using two automatic TLD readers (Model UD 710-A). Data from the readers is transmitted to a Hewlett Packard 9825 where raw data is stored on tape and print-ed out as hard copy. A manual reader is used to process the extremity badoes. The Landauer dosimeters are sent off-site for processin The inspector toured the dosimetry processing area and the records area and found these facilities to be adequate for persontici dosim-etry during routine operations. In the event of an accident, the manual reader with the HP 9825 and a portable printer are available for relocation into the Technical Support Cente .3 Calibrations The licensee calibrates the Panasonic dosimeters with a Cesium-137 Gamma Source. Exposure rate is quantified by use of a condenser R-meter. The licensee calibrates all personnel dosimetry in free air. Therefore, to previde a more accurate assessment of delivered dose-to the dosimeter, the licensee conducted experiments to deter-mine the appropriate Cx value (converting exposure to delivered dose)

to use in this situation. The licensee determined that an appro-priate Cx value~to use was 0.966, .because the Cx value of 1.03(ANSI -

N13.11-1983 value) included a backscatter correction factor which the licensee has effectively eliminated by performing free air calibra-

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tions. The inspector determined, through review of the data, that the licensee had appropriately corrected their Cx value in order to provide more accurate assessment of delivered doses due to gamma exposur .4 Procedures The inspector reviewed the licensee's procedures for the implemen-tation of the dosimetry program. The procedures were reviewed for content and clarity. The inspector found the following:

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The procedures lacked continuity for the operational steps in the dosimetry processing program. This made them difficult to follow and understan The procedures contained sections within them that addressed several different functional areas of the radiation protection organization. This tended to make the procedural steps seinewhat incoherent and confusin _

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The procedures did not identify all tasks' associated with the.dosim-

etry program. Also, the criteria for rejection of data'or quality control test results were not explicitly state The procedures stated that corrective actions would be taken in certain situations, but the corrective-actions were not speci-f 2 The, procedures generically addressed all dosimeters used at the site, and did not provide clear guidance for handling each specific dosimeter typ There were no. procedures developed or established to incorpo-rate the new model 812 AQ dosimeters into the personnel dosim-etry syste The inspector. discussed the above findings with the licensee, and the need to provide procedures for the new model dosimeters (the 812 AQ). g The licensee stated that the procedures to implement the dosimetry \

program needed overhauling and upgrading, and indicated that this will be done. The status of the procedure upgrade will be reviewed in a future inspection .

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3.5 Dose Assessment .

The licensee uses no algorithms to determine deep and shallow dose The licensee uses lithium borate TLD material in a plastic holder,

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_and assumes tissue equivalence.for their IL .

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Either element 3 or element 4 (whichever measures the larger de-livered dose) is used to assign the deep dose. Element 2 is not used in dose assignmen Skin dose is assigned by using the reading of element #1 of the dosim-eter, after suitable conversion to units of dose. The inspector pointed out that this practice could result in substantially under-estimating the skin dose, possibly by an order of magnitude or more, because of the wide variation in beta spectral energies seen in nuclearpower plant environments. The licensee stated that they disagreed for two reasons. First, they intend to use protective clothing whenever there is a potential 'for any significant exposure to beta radiation, thus making measuring the beta component of the skin dose unnecessar Second, they stated that, although NRC FORM-5 recommends that skin dose be measured under an absorber of 7 milli-grams per square centimeter thickness, they believe this to be an un-realistic depth. The thickness of the filter over element #1 of their dosimeter, namely 18 milligrams per square centimeter or greater is a more appropriate thickness, particularly considering that experimen-tal data in the technical literature supports this view. The inspec-tor stated that, although the licensee is certified by NVLAP,

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tio data was available at the time of this inspection to demonstrate the licensee's capability to monitor skin dose at their facility in accordance with the specifications in the applicable regulatory requirements as specified in NRC Form 5. This is required to ,

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demonstrate compliance with 10 CFR 20.101 requirements. This item will therefore be left as an unresolved item to be reviewed in a future inspection (50-286/87-02-01).

3.6 Quality Control / Quality Assurance Program The inspector reviewed the quality control program for dosimetry  !

performance. The licensee provided adequate checks on dosimetry data  ;

through the use of spike quality control badges which were read before and after each group of dosimeters was processed. Further-more, the licensee processed weekly and monthly spikes of all badges

' used at the site. However, all data analyses were performed manually, l without the benefit of computer programs to scan for anomalous dat '

The-inspector stated that this method may. increase .the opportunity . ,

fo'r personnel mistakes and errors. The licensee stated that computer  :

programs were under development to eliminate the manual manipulation of data for QC checks as.well as remove the manual conversion of . ..

dosimetry results to personnel records. This will be reviewed in a

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future inspectio The inspector reviewed the licensee's quality assurance annual aidits l for the personnel dosimetry program. One audit to review documen-tation and recordkeeping had been performed in October, 1985. No additional audits for the review of the adequacy of the personnel i

dosimetry program had been performed. The licensee stated that an

! audit of the dosimetry program was scheduled to take place a few ( weeks following this inspection. The licensee further stated that efforts would be made to ensure that regular quality assurance audits would take place in the futur .7 Documentation and Recordkeeping The inspector reviewed the licensees program for documentation of dosimetry results and the required recordkeeping. No violations were identified in this review. However, it was noted (see also paragraph 3.6) that all data transfer from dosimetry data to personnel records

was performed manually by entering dosimetry results into Hewlett.

i Packard 1000 computer. The licensee stated that they were developing

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a software interface to tie the two systems together and eliminate l the manual insertion of data, thereby reducing the potential for

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transcription errors.

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-~ _ _ .0 _ Exit Interview The inspector met with licensee representatives at the conclusion of the '

inspection on January 29, 1987. The inspector summarized the purpose, scope and findings of the inspectio l

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