21
. - , ' l 4. i - . x ~ . Richard A.Uderitz Public Service Electric and Gas Company P.O Box 230. Hancocks Bridge, NJ 08038 000 935 6010 Vice President - Nuclear August 4, 1983 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Dear Mr. Martin: NRC INSPECTION 50-311/83-14 SALEM GENERATING STATION NO. 2 UNIT APRIL 17 THRU 20, 1983 The following is our response to the notice of violation identi- fled as a result of the inspection conducted on April 17 - 22, 1983. This response was delayed in the interest of completeness as. discussed with Mr. J. R. White of your staff. ITEMS OF VIOLATION: Item A 10CFR 20.103(a)(3) requires that licensees use suitable |- measurements of concentrations of radioactive material in air for detecting and evaluating airborne radioactivity for purposes , I of determining compliance with the requirements of 10CFR 20.103. 10CFR 20.103(a)(1) provides quarterly limits for intake of airborne radioactivity. Contrary to the above: On April 16, 1983, during three separate drilling and cleaning operations of a nozzle dam stud located inside the No. 22 steam generator, no measurements of the concentrations of radioactive materials present therein were made for purposes of determining compliance with 10CFR 20.103. Personnel entered the steam generator immediately before and af ter the drilling to clean the area being drilled with an air gun. This is a Severity Level IV violation (Supplement IV). 8309200415 830907 ' PDR ADOCK 05000311 PM G . _ . . - - _ . . - - - - - .

measurements of concentrations of radioactive material in air

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Richard A.Uderitz Public Service Electric and Gas Company P.O Box 230. Hancocks Bridge, NJ 08038 000 935 6010Vice President -Nuclear

August 4, 1983

Mr. Thomas T. Martin, DirectorDivision of Engineering and Technical ProgramsU. S. Nuclear Regulatory Commission631 Park AvenueKing of Prussia, Pennsylvania 19406

Dear Mr. Martin:

NRC INSPECTION 50-311/83-14SALEM GENERATING STATIONNO. 2 UNITAPRIL 17 THRU 20, 1983

The following is our response to the notice of violation identi-fled as a result of the inspection conducted on April 17 - 22,1983. This response was delayed in the interest of completenessas. discussed with Mr. J. R. White of your staff.

ITEMS OF VIOLATION:

Item A

10CFR 20.103(a)(3) requires that licensees use suitable|- measurements of concentrations of radioactive material in air

for detecting and evaluating airborne radioactivity for purposes,

I of determining compliance with the requirements of 10CFR 20.103.10CFR 20.103(a)(1) provides quarterly limits for intake ofairborne radioactivity.

Contrary to the above:

On April 16, 1983, during three separate drilling andcleaning operations of a nozzle dam stud locatedinside the No. 22 steam generator, no measurements ofthe concentrations of radioactive materials presenttherein were made for purposes of determiningcompliance with 10CFR 20.103. Personnel entered thesteam generator immediately before and af ter thedrilling to clean the area being drilled with an airgun. This is a Severity Level IV violation(Supplement IV).

8309200415 830907'

PDR ADOCK 05000311PMG

. _ . . - - _ . . - - - - - ._

_ - ;*

.

,, , -

'

. .

.

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -2- 8/4/83

Reply to Item A

Elevated contamination levels in the No. 22 Steam Generator (SG)were the result of a Westinghouse Bolt Removal project. Theloose debris from this and other work became airborne when thenearby No. 22 Reactor Coolant Pump (RCP) was test run. This RCPwill draw 20,000 cubic feet of air per minute for cooling pur-poses. The RCP is located adjacent to the SG, and with thesudden change of air flow, the contamination from the SG and SGtent area was drawn out by the RCP motor toward the RCP area.The pe::sonnel that were in the vicinity of the RCP were exposedto unexpected radioactive airborne concentrations which werehigher than normal.

-It should be noted that an air sample from the waterbox wastaken immediately prior to the drilling operation. Addition-ally, numerous samples had been taken previously in the SG tent,bowl, and platform areas during this outage and during previousoutages revealing elevated airborne radionuclide concentrationsin the SG waterbox. As a result of these observations, all SG" bowl" work is performed in multiple sets of protective clothingwith airline-full face respiratory protective equipment. Sincethe SG " jumps" are of very short duration and the turn-aroundtime is very large on determining activity levels from airsamples when compared to jump times (several minutes, typicallytwo minutes), the practicality of taking individual samples for,3

/ each " jump" is limited.-

~

4 --

The requirements of 10CFR 20.103(a)(b) state that suitablemeasurements of airborne concentrations of radioactivity must bemade for determining compliance with the requirements of 10CFR20.103(a)(1). It should be noted that measurements by them-selves do not ensure compliance with the exposure limits, butrather the preventive action taken prior to the work dictateswhether compliance is achieved. In other words, when airborneconcentrations increase, various levels of respiratory protec-tive equipment can be utilized to prevent exceedance of theregulatory limits. If the concentration levels exceed thoselevels for which the highest rated respiratory protectivedevices can protect against for a given exposure duration, thenth e activity must be terminated and the individuals must beremoved to an area of lower airborne contamination.

Since the drilling operation workers were already employing air-supplied full-face respiratory protection (with a protectionfactor of 2000) and their " stay" time was restricted below 10minutes (usually 6 minutes), the expected variations in airborneconcentrations in the SG would not jeopardize our ability tolimit the amount of radioactivity inhaled below the quarterly

. _ _ _. .- _ __

.-

.e ..

'

. .

.

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -3- 8/4/83

limits (520 MPC-hours). This conclusion is borne out by the |whole body counts done on these " jumpers." The airconcentration which would require us to suspend operations isseveral orders of magnitude greater than any observed airconcentration at Salem station including the SG bowl (waterbox). |The quantity of removable contamination to achieve such elevated I

concentrations is very high (on the order of tens of curies). |

Since the total potential source term for high airborne activityin the steam generator is finite and the waterbox had beenhydrolazed prior to this evolution, it appears that our airsampling measurements were adequate to ensure compliance with

|10CFR 20.103. l

However, we are investigating potential improvements in ourmeans to detect changes in conditions within the SG bowl whichmight warrant suspension of work activities. As a result of ourreview of the events occurring on April 16, 1983, several areasof improvement in our containment air sampling program during

,

outages have been identified. Although at least 17 air samples |were taken during the period of interest, it appears that we can |enhance our knowledge of changing conditions within containment. |

This improvement requires prompt recognition of conditions |

changing respiratory requirements for various operations incontainment. The specific actions taken by PSE&G in regards to |

this matter are discussed below.

Actions to Prevent Recurrence:

1. The Radiation Protection Department will revise theprocecare governing surveys (RPI 4.001) to ensure samplesare taken from the containment building at least once per |hour during routine containment outage conditions where the

| potential for high airborne radioactivity exists. Thisprocedure will be revised by September 30, 1983.

2. Direct-indicating air monitoring devices will be evaluatedfor use to monitor changing airborne concentrations nearsources of high contamination during the outages. Forexample, recording air monitor devices can be employed forthe SG platform area in the future. Additionally, we areinvestigating other means to verify that the respiratoryprotection provided to workers within the SG bowl is

,

|suitable to maintain compliance with 10CFR 20. The |improvements that will be adopted will conform to ALARArequirements as well as to proper sampling practices (e.g.,the ability to differentiate between respirablecontamination and gross large-particle contamination).These actions will be completed by the next refuelingoutage on Unit No. 2.

.

..+ .

. .

*,.

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -4- 8/4/83

3. The ALARA program at Salem Generating Station (SGS) is beingstrengthened to provide better pre-job ALARA review. for alljobs requiring a Radiation Exposure Permit. The enhancedpre-job ALARA review will include the incorporation ofspecific air sampling requirements for jobs having thepotential for changing airborne concentrations.Improvements and procedural modifications are scheduled forimplementation by January 19, 1984.

Item B

10CFR 20.103 states in paragraph (b), in part, "The licenseeshall, as a precautionary procedure, use process or otherengineering controls, to the extent practicable, to limit con-centrations of radioactive materials in air to levels belowthose which delimit an airborne radioactivity area as defined in20.203(d)(1)(ii) ..."

Contrary to the above:

On April 16, 1983, an installed airborne radioactivityremoval system was not used to limit airborne radio-activity concentrations inside the No. 22 Steam Gen-erator or in the vicinity thereof. Airborne radio-activity concentrations measured in the work vicinityranged from 52 to 168 times the value specified in20.203(d)(1)(ii). This is a Severity Level IV viola-tion (Supplement IV).

Reply to Item B

At 1650 on April 15, a Radiation Protection (R.P.) Supervisorrequested that No. 22 Iodine Removal Unit (IRU) be placed inservice for a test. As a result of a miscommunication betweenthe Radiation Protection and Operations Departments, the IRU wasnever placed in service. However, the R.P. Department recordedthe Public Address (PA) announcement by Operations in the shiftlog (the announcement was incorrect), as verification that theIRU was operating when SG work began approximately 20 hourslater.

It is difficult to determine whether or not the IRU would haveprevented the personnel contamination to those in the RCP areain this particular event. Personnel in the SG tent area wereprotected, however, by their respiratory equipment. Based onour evaluation of events, the Reactor Coolant Pump (RCP) motortest run may have rendered any available air removal units

s

T'

e

., . .

. .

.

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -5- 8/4/83

inadequate. Nevertheless, it is believed that properengineering controls were not exercised. The most significantcause of the contamination spread appears to be the operation ofthe nearby RCP. The RCP motor test run should thus not beallowed to take place concurrently with any high contaminationjob within containment.

Actions to Prevent Recurrence:

1. A form has been developed to document requests to theOperations Department to place in service any system thatthe Radiation Protection Department feels will aid inmaintaining exposures ALARA. This should assure thecommunications are complete.

2. Improved communications and a strengthened ALARA programshould promote the scheduling of plant evolutions to avoidany adverse impact on maintenance work in progress.

The attachments to this letter contain more detailed materialthan our summary previously provided to the NRC inspectors. Theattachments provide clarification regarding the interpretationof which MPC-hours were used from the various methods available.

Sincerely,

kh

Attachments

CC: Director, Office of Inspection and EnforcementNuclear Regulatory CommissionWashington, D.C. 20555

Mr. Donald C. FischerLicensing Project Manager

Mr. Leif NorrholmSenior Resident Inspector

.

V . .. ..

.

Rich:rd A. Uderitz Pubhc Seri,u Electric and Gas Cort.Nny P.O Box 236 Horrocks Bridy, NJ 03038 6fB 935 6010v.ce President -UJC|PM

August 4, 1983

Mr. Thomas T. Martin, DirectorDivision of Engineering and Technical ProgramsU. S. Nuclea r Regulatory Commission631 Park AvenueKing of Prussia, Pennsylvania 19406

Dear Mr. Martin:

NRC INSPECTION 50-311/83-14SALEM GENERATING STATIONNO. 2 UNITAPRIL 17 THRU 20, 1983

The following is our response to the notice of violation identi-fied as a result of the inspection conducted on April 17 - 22,1983. This response was delayed in the interest of completenessas discussed with Mr. J. R. White of your staff.

ITEMS OF VIOLATION:

Item A

10CFR 20.103(a)(3) requires that licensees use suitablemeasurements of concentrations of radioactive material in airfor detecting and evaluating airborne radioactivity for purposesof determining compliance with the requirements of 10CFR 20.103.10CFR 20.103(a)(1) provides quarterly limits for intake ofairborne radioactivity.

Con t ra '. to the above:

On April 16, 1983, during three separate drilling andcleaning operations of a nozzle dam stud locatedinside the No. 22 steam generator, no measurements ofthe concentrations of radioactive materials presenttherein were made for purposes of determiningcompliance with 10CFR 20.103. Personnel entered thesteam generator immediately before and af ter thedrilling to clean the area being drilled with an airgun. This is a Severity Level IV violation(Supplement IV).

.

.

*< .

.. ..,

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -2- 8/4/83

Reply to Item A

Elevated contamination levels in the No. 22 Steam Generator (SG)were the result of a Westinghouse Bolt Removal project. Theloose debris from this and other work became airborne when thenearby No. 22 Reactor Coolant Pump (RCP) was test run. This RCPwill draw 20,000 cubic foot of air per minute for cooling pur-poses. The RCP is located adjacent to the SG, and with thesudden change of air flow, the contamination from the SG and SGtent area was drawn out by the RCP motor toward the RCP area.The personnel that were in the vicinity of the RCP were exposedto unexpected radioactive airborne concentrations which werehigher than normal.

It should be noted that an air sample from the waterbox wastaken immediately prior to the drilling operation. Addition-ally, numerous samples had been taken previously in the SG tent,bowl, and platform areas during this outage and during previousoutages revealing elevated airborne radionuclide concentrationsin the SG waterbox. As a result of these observations, all SG" bowl" work is performed in multiple sets of protective clothingwith airline-full face respiratory protective equipment. Sincethe SG " jumps" are of very short duration and the turn-aroundtime is very large on determining activity levels from airsamples when compared to jump times (several minutes, typicallytwo minutes), the practicality of taking individual samples for3

'

/ each " jump" is limited. ~ ~~

The requirements of 10CFR 20.103(a)(b) state that suitablemeasurements of airborne concentrations of radioactivity must bemade for determining compliance with the requirements of 10CFR20.103(a)(1).. It should be noted that measurements by them-selves do not ensure compliance with the exposure limits, butrather the preventive action taken prior to the work dictateswhether compliance is achieved.- In other words, when airborneconcentrations increase, various levels of respiratory protec-tive equipment can be utilized to prevent exceedance of theregulatory limits. If the concentration levels exceed thoselevels for which the highest rated respiratory protectivedevices can protect against for a given exposure duration, thenthe activity must be terminated and the individuals must beremoved to an area of lower airborne contamination.

Since the drilling operation workers were already employing air-supplied full-face respiratory protection (with a protectionfactor of 2000) and their " stay" time was restricted below 10minutes (usually 6 minutes), the expected variations in airborneconcentrations in the SG would not jeopardize our ability tolimit the amount of radioactivity inhaled below the quarterly

.

*a .

.

. ..,

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -3- 8/4/83

limits (520 MPC-hours). This conclusion is borne out by thewhole body counts done on these " jumpers. " The airconcentration which would require us to suspend operations isseveral orders of magnitude greater than any observed airconcentration at Salem station including the SG bowl (waterbox).The quantity of removable contamination to achieve such elevatedconcentrations is very high (on the order of tens of curies).Since the total potential source term for high airborno activityin the steam generator is finite and the waterbox had beenhydrolazed prior to this evolution, it appears that our airsampling measurements were adequate to ensure compliance with10CFR 20.103.

However, we are investigating potential improvements in ourmeans to detect changes in conditions within the SG bowl whichmight warrant suspension of work activities. As a result of ourreview of the events occurring on April 16, 1983, several areasof improvement in our containment air sampling program duringoutages have been identified. Although at least 17 air sampleswere taken during the period of interest, it appears that we canenhance our knowledge of changing conditions within containment.This improvement requires prompt recognition of conditionschanging respiratory requirements for various operations incontainment. The specific acticns taken by PSE&G in regards tothis matter are discussed below.

Actions to Prevent Recurrence:

1. The Radiation Protection Department will revise theprocedure governing surveys (RPI 4.001) to ensure samplesare taken from the containment building at least once perhour during routine containment outage conditions where thepotential for high airborne radioa'ctivity exists. Thisprocedure will be revised by September 30, 1983.

2. Direct-indicating air monitoring devices will be evaluatedfor use to monitor changing airborne concentrations nearsources of high contamination during the outages. Forexample, recording air monitor devices can be employed for

,

the SG platform area in the future. Additionally, we areinvestigating other means to verify that the respiratoryprotection provided to workers within the SG bowl issuitable to maintain compliance with 10CFR 20. Theimprovements that will be adopted will conform to ALARA

,

' requirements as well as to proper sampling practices ( e. g . ,the ability to differentiate between respirablecontamination and gross large-particle contamination).These actions will be completed by the next refuelingoutage on Unit No. 2.

|

.-

*. -.

.. ..,

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -4- 8/4/83

3. The ALARA program at Salem Generating Station (SGS) is beingstrengthened to provide better pre-job ALARA review for alljobs requiring a Radiation Exposure Permit. The enhancedpre-job ALARA review will include the incorporation ofspecific air sampling requirements for jobs having thepotential for changing airborne concentrations.Improvements and procedural modifications are scheduled forimplementation by January 19, 1984.

Item B

10CFR 20.103 states in paragraph (b), in part, "The licensceshall, as a precautionary procedure, use process or otherengineering controls, to the extent practicable, to limit con-centrations of radioactive materials in air to levels belowthose which delimit an airborne radioactivity area as defined in20.203(d)(1)(ii) "

...

Contrary to the above:

On April 16, 1983, an installed airborne radioactivityremoval system was not used to limit airborne radio-activity concentrations inside the No. 22 Steam Gen-erator or in the vicinity thereof. Airborne radio-activity concentrations measured in the work vicinityranged from 52 to 168 times the value specified in20.203(d)(1)(ii). This is a Severity Level IV viola-tion (Supplement IV).

Reply to Item B

At 1650 on April 15,'a Radiation Protection (R.P.) Supervisorrequested that No. 22 Iodine Removal Unit (IRU) be placed inservice for a test. As a result of a miscommunication betweenthe Radiation Protection and Operations Departments, the IRU wasnever placed in service. However, the R.P. Department recordedthe Public Address (PA) announcement by Operations in the shiftlog (the announcement was incorrect), as verification that theIRU was operating when SG work began approximately 20 hourslater.

It is difficult to determine whether or not the IRU would haveprevented the personnel contamination to those in the RCP areain this particular event. Personnel in the SG tent area wereprotected, however, by their respiratory squipment. Based onour evaluation of events, the Reactor Coolant Pump (RCP) motortest run may have rendered any available air removal units

.

.

c. . . .

.. ..,

Mr. Thomas T. Martin, DirectorU.S. Nuclear Regulatory Commission -5- 8/4/83

inadequate. Nevertheless, it is believed that properengineering controls were not exercised. The most significantcause of the contamination spread appears to be the operation ofthe nearby RCP. The RCP motor test run should thus not beallowed to take place concurrently with any high contaminationjob within containment.

Actions to Prevent Recurrence:

1. A form has boon develop 3d to document requests to theOperations Department to place in service any system thatthe Radiation Protection Department feels will aid inmaintaining exposures ALARA. This should assure thecommunications are complete.

2. Improved communications and a strengthened ALARA programshould promote the scheduling of plant evolutions to avoidany adverso impact on maintenance work in progress.

The attachments to this letter contain more detailed materialthan our summary previously provided to the NRC inspectors. Theattachments provide clarification regarding the interpretationof which MPC-hours were used from the various methods available.

Sincerely,

/4G.7x~e

A6p'

Attachments

CC: Director, Office of Inspection and EnforcementNuclear Regulatory CommissionWashington, D.C. 20555

Mr. Donald C. FischerLicensing Project Manager

Mr. Leif NorrholmSenior Resident Inspector

_ _ .

ATTACHMENT 1.

.. .

DDSE CALCULATION RESULTS. ..

and CALCULATIONAL METHOD

50 Year * 5 0 Y e ar * **.

Count Time /Date Whole Body Dose Lung DoseName (mrem) (mr em)

- .

A 13:49, 4/17 4.4 .344*

. ,6 16:17, 4/17 2.9 241

C 16:07, 4/17 1.8 207

p 17:07, 4/17 1.8 175

E 15:05, 4/17 0.7 53

F 9:37, 4/18 0.7 12- ,

C- 12:33, 4/17 2.1 .121

l+ - 15:18, 4/17 0.7 22-

,_

[ 1 7_: 0 4 , 4/16 0.4 34'

,

3~16:09, 4/17 0.5 20

K 10:03, 4/17 0.7 17

.

Based on the assumption that particles inhaled are soluble.*

** Based on the assumption that particles inhaled are insoluble..

The bioassays performed in the week following the exposures supported theassumption that the airborne activity was in the form of insolublepar ticulate s. With insoluble par ticulates, the lung will receive most ofthe dose,and therefore become the organ of concern. To be conservative,

calculations were performed with the assumption that 100 percent of the. radioactive particulates were in an insoluble form. In addition, another

calculation was performed in order to ascertain an estimate of the dosewhich.would be delivered if the particulates were (or became) soluble. In

this situation, the radionuclides would be distributed throughout the bodyand make the whole body the " organ of concern". The following page defines

the equation used for these calculations.. __._ - _ _ . ,

In accordance with 10 CFR 2.790 the names ofindividuals and their social security numbers havebeen removed to avoid an unwarranted invasion of .

personal privacy.f

.

_

ATTACHMD:T 1 Cont' d*

, , ,

h doses.. ..

The equation below taken from ANSI-N343, was used to calculate t e' resulting from this event.

'.51.2 g(t)f2 exp (At) E (1-e xp(-18 250 A) )

-,

D, Am

50 year _ dose based on, a single in- vivo measurement=D,(dis /uci-day)conversion factor; (g-rad /Mev) x

51.2. =

time of measurementradioactivity in total body at~q(t) =

in organ of reference of the radioactivity in total bodyfraction:f2 =

~ lideeffective absorbed energy per disintegration of a radionuc=E (Table 4, ANSI-N343 )

X d 0.693/T-eff (days-1), ICRP-2 values used for soluble, and 120 dayfor insoluble (ICRP-10 assumption)biological halflife used,,

m . mass of or,gan of reference=

18250 = days per 50 yearsintake and in-vivo measurement (days)

time betweent ' =

'- *

:- .

4

'O

4

6

9

e

"e

*'T'Tw-*w%y _ * ~' Twrr w- p---

ATTACHMENT 2*

.

.. .

.-., MPC - HOUR ASSIGliMENTS FOR INDIVIDUALS..

INTEiciALLY CONTAMINATED ON APRIL 16, 1983

Individuals MPC - hrs based on MPC-brs, based

Name_

Stay-time and Air saniples on whole Body Countg

[A'

24.3 43.0--

6 1.0 29.5 -- .

C. 38.2 25.5 -.

E 11.5 22.9

D 0.6 21.7 -

F 2.3 17.9

Cr 21.7 14.5 -

H 4.6 10.4 -

|s

A. <0.1 6. 5 -'

7 ~

12.3 2. 6 -

K 1.2 2.2 -

MPC - HOUR ASSIGNMENT METHODS'

Methods of assigning MPC - hrs to the dose records of internally contaminatoindividuals are described below:A. - S tay-Time. Method : c 3

'

*:.

. This methodeis included .in the Radiation Protection Procedure Number RP;11.011. The formula used is as follow ~s:

Time spent * airborne activity **

" "' " "---- -- . - . - - - - -MPC - hour s =" Protection. factor for respiratory equipment

.

The ' time spent in the area is obtained frcm the appropriate REP*

Sign-In Sheet.

** After GeLi analysis 'a ' "per cent MPC" number is included on the comput-printout. This number is calculated by dividing MPC values into eacrespective radionuclide activity and summing to give a total "percenMPC". The percent MPC number is used whenever possible in the above-formula. - - - - - - _ _ . - - . -- - -

In accordance with 10 CFR 2.790 the names of ,

individuals and their social security numbers havebeen removed to avoid an unwarranted invasion ofpersonal privacy.

~ ~ -

. .

ATTACHMENT 2'* *

- .. ..

B. Whole Body Count MethodN343. TheThis method is based on assumptions given in ICRP2 and ANSI -

-

formula used and the assumptions made are given below..

uCi in the lung .

'

MPC - hours = -[uCi/cc per MPC) x 1.25E6 6c7Fr x 0.125. '

This calculation is repeated for each radionuclide with the results-

summed to give an MPC-hour assignment.

1.25E6 is the standard working breathing rate.-

0.125 is based on the assumption that 12.5 percent of the radioactive-

particles inhaled are left in the lungs after 24 hours.The uCi number is obtained from whole body count data on the lung-

bur d en , approximately 24 hours after the initial exposure.*

C. Whole Body Count Printout

The formula described in Section B above is included in the Whole BodyCounter computer program and, as a result, an MPC-hour value is given on" time since exposur$the Whole Body Count Report (printout). However, a

value is not in cor pora ted into the computer formula. The RadiationProtection staf f has determined that since the "12.5 percent assumption"should only be used after 24 hours, the only MPC-hour value for the WholBody Counter computer printout, which can be considered accurate, is th@. computer number calculated from the lung activity 24 hours afterexposure . -

NOTE-Q .

Standard practice at Salem is to assign MPC-hou'rs based on the' stay-tim @~

- Method.- In this case the 11 ~ individuals with'-ipternal exposures 'above .the procedural action level for further bioassay analysis ' ere assigned'w

MPC hours based on -the (manually calculated) Whole-Body Count Methodversus the stay-time method to improve accuracy.

.

t

* *

I

T' WIT'rfi.*22,4 3.

.' Initial 1ssicned'

Name SSN Co. WBC P D C-- P r E. -,

Ba s e 6___oW__t a y Wmira

I. Catalytic 4/17 ,3.65|

2. Catalytic 4/18 0.20,

.. ..

3- Catalytic 4/17 2.76,

#1 PSE&G 4/17 2.76O,

.

P.ydro Nuclear Ser. 4/16 21.7*

5 Rad Services Inc. 4/18 33.76..

b Catalytic 4/17 0.20'

'7 Catalytic 4/17 0.20w>

B .E o HAP 4/17 4.30

9 %E5 HAP 4/17 < O .1O U.,=.

m "5 >Westinghouse 4/16 3.67"10

m

// 5 " ." Westinghouse 4/17 4.27cX

/ 2. c ." 3 Catalyt.ic 4/17 < 0.1.c u u#/3 8E ! Catalytic 4/17 0.20

''-

oeulf R*5 Catalytic 4/17- 3.09

.- 2

"}5 Catalytic 4/17 4.7515 .

/6 $85 Catalytic 4/17 < 0.1

/7 OD3 Catalytic 4/17 1.300 0

/E 56%. Hydro Nuclear Ser. 4/17 1.89g-

17 *ESMj Catalytic 4/17 4.70es :e >

26 E m l 'E . Rad Services Inc. 4/18 < 0.1m->a.

l'S@- _ Rad Services Inc. - 4/17 3.997-(Oo m; ,

m i.L':8 ' c m .~Catalytic...

. ~.. /17~ < 0 . l~ .5z.2. _ - 4

. - .-

7'31? .c,.i Ej 5 1 .~ R,ad' Services Inc. ~ . 54/18 < 0. 1 *

_ .O a;-

29 PSE&G 4/17 -1.20

25 , Catalytic 4/17 1.44,

~

2. 6 Catalytic 4/16 1.41

27. Catalytic 4/17 5.67

28 Catalytic 4/18 1.40

17 Catalytic 4/17 1.24

3o PSE&G 4/18 < 0 .131 PSE&G 4/37 0.24

31 Catalytic 4/17 1.50

33 Westin9 ouse 4/16 1.54h

'

Based on Whole Body Count Data and*

Rrarcin@m coliven in Attachment 2, Part_B RcV- 1~

. < - - ~ ~ s 3n2z w-

,._ . . ..-

:!!ame SE!; Co. WBC MPC-ErE-

(Ba sed on 5 3. W' '

sun).

31 Rad Services Inc. 4/18 1.55~ ~

35 pSE&G 4/18 .0.58,

3L . Combustion Eng. 4/17 4.10-

'

3'? Catalytic 4/17 0.42'

38 Catalytic 4/17 3.90,

31 Catalytic 4/17 0.74

40 Catalytic 4/17 0.68.

4I Catalytic 4/17 4.1

41 Catalytic 4/16 8.5.

CJ l

43 $% j Combustion Eng. 4/17 0.20C O ;

44 ! Catalytic 4/17 1.10mc

% L. oI Catalytic 4/18 7.74'/ 5 S '",,

mga4G nee Catalytic 4/18 0.40'

m -

't 7 "Do Catalytic 4/17 1.11s as .- m ~ 0 .1<M 15 5 c Westinghouse 4/15,

49 S Kenper Ins. 4/18 <0.1rs a

PSE6G 4/18 1.2050 d % $,..

5. EEc Rad Services Inc. 4/18 < 0.1ome

52 o s. o Catalytic 4/16 3.761

a-5} r$ Cooperheat 4/18 0.36

,

aam .

51 'g .a o D Rad Services Inc. 4/18 <0.1aam

55 8 * o .R Catalytic 4/17 <0.1C M GI S.

50 .@ % 3 " Rad Services Inc. 4/18 4.95t. s g ,- ,

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63 Catalytic 4/17 1.13

64 Cooper Heat 4/17 4.59

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0.41

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x 1-, - - . _ .

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formula given in Attachment 2, Part B

Rev. 1,

.

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125 Catalytic 4/16 *2.92

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127 Catalytic . 4/17 2.65,

I28 Catalytic 4/17 4.16,

IM Hydro Nuclear Ser. '4/17 2.67

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372 Catalytic 4/17 <0.1,

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5@o e s-

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215 Westinghouse . 4/17 1._25

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217 Westinghouse 4/15 3.14

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