IR 05000213/1987017

Insp Rept 50-213/87-17 on 870727-31.No Violations or Deviations Noted.Major Areas Inspected:Licensee Radiation Protection & Mgt Controls,Personnel Selection,Qualifications & Training,Radwaste Mgt & Facilities & Equipment

ML20235A341
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/08/1987
From:	Frank Akstulewicz, Bicehouse H, Kottan J, Pasciak W, Sherbini S, Zibulsky H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235A298	List: IR 05000213/1987017 ML20235A295
References
50-213-87-17, NUDOCS 8709230280
Download: ML20235A341 (17)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-17 Docket N License N DPR-61 Category C Licensee: Connecticut Yankee Atomic Power Company Facility Name: Haddam Neck Power Station Inspection At: Haddam Neck, Connecticut Inspection Conducted: July 27-31,1987 Inspectors: h,W Q 9-bY7 H. Zibulsky\, CQ m st '

date (u$' , OAlb f 8-87 J. Kottan, Laboratory Specialist date aw H.~ Bicehouse, Radiation Specialist 9hk7 date (L uhl S. Sherbini, Radiation Specialist 0 9Ne7 date

/?A u~LA-F. AkstTJlewicz, Project /MaMger, NRR 9/8/ev

/date Approved by: M cr> n !8 E E Pasciak, Chief, Effluents Radiation /date Protection Section, DRSS

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Inspection Summary: Inspection July 27-31, 1987, (Report No. 50-213/87-17)

Areas Inspected: Special announced safety team inspection by a regionally and headquarters based team of inspectors of the licensee's radiation protection and management controls; personnel selection, qualifications and training; exposure control: radioactive waste management; ALARA program; and facilities and equipmen Results: No violations or deviations were identifie The licensee appeared to be systematically improving performance in the ALARA are $OO213 PDR ADOCK PDR G

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DETAILS 1. Personnel Contacted 1.1 Licensee Personnel

• D. Miller, Jr. , Station Superintendent

• H. Clow, Health Physics Supervisor

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• E.~ DeBarba, Station Services Superintendent

• G. Goncarovs, Radiochemist

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• R. Haight, Radioactive Material Handling Supervisor

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C. Martin, Engineer, Mechanical Engineering

• W. Nevelos, Radiation Protection Supervisor

• M. Sweeney, Radiation Protection Supervisor

• M. Hornyak,'NUSCO - Quality Services

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M.~ Quinn, Chemistry' Supervisor S. Matthess, Associate Chemist L. Silvia, Associate Health Physicist-R. Groves, Assistant Radiation Protection Supervisor J. Chiare11a, Asst. Instrumentation and Controls Supervisor R. . Haberern,' Auxiliary. 0perator F. Yeltan, Asst. Radiation Protection Supervisor J. Powell, ALARA Coordinator H. Siegrist, Supervisor, Radiation Protection, NUSCO A. Vomastek, Asst. Radiation Protection Supervisor M. Brown, Technical Training Manager J. Maher, General Nuclear Training Supervisor P. Pritchard, Health Physics Instructor D. Mitchell, Health Physics Instructor M. Totora, Chemistry Instructor l D. Burns, Recruitment Assistant Other licensee personnel were also contacted or interviewed during the inspectio .2 NRC Personnel A. Asars, Resident Inspector

• T. Shedlowsky, Senior Resident Inspector

• W. Pasciak, Inspection Team Leader, RI

• H. Zibulsky, Chemist, RI

• J. Kottan, Laboratory Specialist, RI

• H. Bicehouse, Radiation Specialist, RI

• S. Sherbini, Radiation Specialist, RI

• F. Akstulewicz, Project Manager, NRR

• Attended the Exit Interview on July 31, 198 . _ - - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ -

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2. Scope of the Inspection This special announced inspection reviewed the licensee's (1) radiation protection organization staffing and management controls; (2) personnel selection, qualification, and training; (3) exposure control including external exposure control, internal exposure control, respiratory protection and surveillance programs; (4) radioactive waste management systems including program responsibility, liquid waste, gaseous wastes and effluent / process instrumentation; (5) ALARA program; and (6) facilities and equipmen The licensee's actions regarding previously identified i items were also reviewe ;

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3. Previously Identified Items 3.1 (Closed) Followup Item (213/85-04-01): Approval of QC procedures and use of control chart The licensee has developed and implemented QC procedures which include the construction and use of control chart .2 (Closed) Followup Item (213/85-04-02): Records of QC split sample I q

program to be improved. The inspector reviewed records of the QC i split sample program and found that the records were maintained as required by the licensee's procedure f j

3.3 (Closed) Followup Item (213/85-04-03): Revise Procedure CHDP1.11 to-include schedule for sending QC samples to vendor lab. The inspector reviewed procedure CHDPl.11 and noted that the procedure had been revised to include a specific frequency for sending QC samples to a vendor laborator .4 (Closed) Followup Item (213/85-04-04): Licensee to investigate methods of improving calibration for analyses of particulate filters by Ge(Li) spectroscopy. The inspector reviewed licensee data, and J noted that the licensee was now preparing particulate filter standards which duplicated actual sample .5 (Closed) Followup Item (213/85-04-05): Improve effluent monitor I calibration program including procedures, discriminator settings, I plateau checks and statistical methods. A review of the licensee's effluent radiation monitor calibration procedures indicated that the procedures contain acceptance criteria, the energy discriminator i settings are documented, a plateau check is performed for the gaseous ,

radioactive effluent radiation monitor, and a statistical method, with acceptance criteria, is used for constructing the calibration Curv .6 (Closed) Followup Item (213/85-04-06): Improve chemistry training

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program. The licensee has implemented an acceptable chemistry train-l ing program.

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' 3.7 (Closed) Unresolved Item (213/86-15-01): Record of gamma analysis not available for liquid release permit 626. The inspector reviewed the gamma analysis for release permit 626, the analysis results had been misfiled by the license .8 (Closed) Followup Item (213/86-15-02): Define abnormal releases and unplanned waste releases. The licensee has modified the appropriate chemistry effluent control procedures to include definitions for abnormal and unplanned release .9 (Closed) Violation (213/86-15-03): Licensee failed to perform analyses at the prescribed frequency. The licensee has modified chemistry effluent control procedures to include weekly analysis of composite samples for continuous releases from steam generator blow down and service water effluent '

3.10 (Closed) Followup Item (213/86-15-04): Procedures improvements to RETS surveillance. The licensee had revised the procedures used for RETS surveillance to incorporate procedure improvements noted by the inspecto . Radiation Protection Organization and Management Controls

4.1 Description The basis for the Radiation Protection program can be found in NE0 ,

Policy Statement Nos. 9 and 25. The current structure of both the corporate (Northeast Utilities Service Company / Connecticut Yankee ]

Atomic Power Company) and the onsite organization are found in Administrative Charts 31.13.20, 31.31.20 and 31.31.2 The current organizational structure and responsibilities do not appear to be described in any administrative procedure. The ,

responsibilities and authorities are described with adequate clarity

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in the position descriptions within the health physics organizatio In this organization, the Health Physics Supervisor reports directly to the Station Services Superintendent (SSS).

The Haddam Neck Plant receives health physics engineering and operations support from Northeast Utilities Services Company (NUSCO),

a wholly owned subsidiary of Northeast Utilitie ihe interrelation-ship between the NUSCO corporate level radiation protection organi-zation, (Radiological Assessment Branch (RAB)), appears to be complementary and planned for efficient use of utility resources )

affecting radiation protection program Some examples of the support services provided by RAB to the plant are:

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.i Radiation' Assessment Shielding Evaluations In-Plant Chemistry Effluent Consequences DBA Consequences-Probalistic Risk Evaluations Environmental Monitoring Radiation Protection Outage Health Physics Support and Supervision Routine and SpecialL0utage TLD Services ALARA Engineering and Review Health Physics Consulting and Training Health Physics Plant Audits Special Projects. and Operations Assignments

' Standards Health Physics Practices and Procedures 4.2 Scope of Responsibilities The responsibilities' assigned to the radiation protection organization are not currently defined in any existing administrative or NEO procedure. The normal responsibilities and authorities are contained in the existing position description I Despite the fact that the responsibilities / authorities are not

located in one location, it does not appear to hinder the actual implementation of any health physics program. It also appeared that the radiation protection organization possesses adequate authority to insure implementation of the radiation protection programs. A review of position descriptions did not identify any discrepancies in the l'

reporting chains and when specifically asked, all personnel were q knowledgeable of the existence of the position descriptions and their conten I 4.3 Staffing Based upon discussions with health physics management and observa-tions of activities and records, radiation protection personnel staffing,both normal and outage management conditions,was determined to be adequate. During normal operation the health physics organi- l zation does not usually rely on any contract assistanc ]

l During refueling outages contract assistance for health physics is 1 L

used. However, direct management of contractors is maintained by the onsite organization, as supplemented by the corporate RAB members.

f.' As mentionea previously, additional technical and management ,

assistance to the onsite organization is provided by the corporate  !

RA Such assistance and the use of the zone approach for control of I

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., 6 radiation areas should provide reasonable assurance that' adequate supervision is-maintained over the. large outage work force as well as providing sufficient technician coverag In' general, the personnel-in supervisory positions appear well qualified for their assigned duties. Staffing levels appear sufficient to' provide adequate numbers of personnel to monitor the functional areas required in the onsite organizatio Technical support to the radiation protection activity provided by-the corporate RAB group appears sufficient in terms of.both technical

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depth and available resource .4 Management Controls There are two methods currently in use at the Haddam Neck Plant to assure management that the health physics program performance standards are being me The first method comes from a corporate commitment to perform audits of the healto physics program which can be found in NE0 Procedure 2.05, " Radiation Protection and Maintaining Occupational Exposures as Low as Reasonably' Achievable." One method of meeting this corporate commitment is that the RAB performs routine audits of the Health Physics Program in accordance with Procedure No. 3 of the Corporate ALARA Program Manual entitled, " Audits and. Appraisals of the Station Health Physics Programs." These audits / appraisals are routinely scheduled on a monthly basis during normal plant operation. During off normal conditions, such as outages, the minimum audit frequency is increased to once per wee The RAB audit team has divided the radiation protection program into 22 distinct categories. While not all categories are examined during

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each audit, all 22 categories are reviewed at least once per yea The scope of the audit program appears sufficient to cover all aspects of the Haddam Neck Plant radiation protection progra Each RAB audit is formally documented and a report prepared Quarterly. The quarterly reports are distributed to but not limited to the Health Physics Supervisor, Station Superintendent and the Senior Vice President - Nuclear Engineering and Operations. Response to the items identified in each audit is. required by the procedure and followup on corrective actions is require The second method derives from a corporate commitment found in NE0

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Procedure 3.10 to perform quality assurance inspections in the health physics area. Following a joint utilities assessment in 1984, the quality assurance audit consists of a review of the RAB audits described above. Every two years, quality assurance audits the RAB  !

to verify that procedures are being implemented as require .

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., 7 5. . Personnel Selection, Qualification and Training The review of the area associated with personnel selection, qualification

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and training was accomplished by visiting both training facilities, Haddam Neck and Millstone, and by discussions with Chemistry and_ Health Physics (HP) instructors, the Program Coordinator for Radiation Worker Trainee

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Programs, Supervisor of General Nuclear Training and the Manager of Technical Trainin The adequacy and' effectiveness of the licensee's training and qualification programs were reviewed against the requirements of Technical-Specifications 6.3 and 6.4, ANSI N18.1-1971 and licensee's procedure .1 Personnel Selection and Qualification The licensee had defined qualification criteria for the Health Physics Helper, Health Physics Technician - Operations and Health Physics Technician - Services positions in their " Bargaining Unit Job Description." The personnel selection is based on minimum requirements, special qualifications and experience, as specified in the job descriptions. With these defined job descriptions anc qualifications,_the licensee has had more experienced people applying for HP job openings. Pruently, the licensee has eleven qualified Senior HP Technician The personnel selection for contractor HPs and Radiation Protection jobs are made through contractor verification of the Technician's resume and the licensee's validation of the Technician's qualification and technical capabilities from his previous employe Personnel selection and qualification criteria are adhered to by the licensee and are within the qualification requirements of the Technical Specifications and ANSI N18.1-1971. The licensee uses these criteria in hiring practices and promotions. These findings indicated well qualified personnel in the organizatio .2 Training Training for HPs is held at Haddam Neck site and at the training facilities at Millstone sit The training of HPs was reviewed against Procedure RAP 6.1-10, Health Physics Personnel Training Program, by review of training records and discussions with HP instructors and Senior HP Technician The training facilities at Millstone include elaborate visual and audible aides, modern classrooms and lecture halls, well equipped i laboratories and instruments and equipment that are duplicates of j those used by the Senior HP Technicians in plant operations. The facility has a gamma spectrometry system for HP and radiological

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., 8 ch'emistry. training. . In the plant, there is a liquid scintillation counter for HP training'.

The training staff has been greatly increased with qualified instructors. . Training schedules have-been extended over a longer period so the required annual training can be met even with a plan outag Senior HP Technicians are given Fire Brigade and First Aid training annually. HP training occurs one week every four months and specialized training for the Senior HP Technicians occurs three weeks every year. On-the-job training (0JT) and continued training are documented. All. documentation of training for each of the HPs is computerized and a training history of each HP, including HP-Supervisors,'is available on a print-ou ~

HP Supervisors receive annual training in Specia11 zed HP courses, e.g. " Beta Dosimetry Under Normal and Accident Conditions" and

" Biological Effects and Risks from Radiation in the Nuclear Power Industry."

Initial chemistry training is approximately twenty-five weeks duration conducted at the training facility (Millstone) and in the plant. The chemistry training program consists of lecture, for theory; laboratory, for hands-on use of instruments; and OJT, for procedural qualification. Continued training is an advanced Chemistry training that is given but is not required for qualification. A formal chemistry requalification program is expected to be introduced to the Chemistry Technicians in 198 Based on this review of the licensee's HP and Chemistry training programs, it was found to be comprehensive and thorough in subject matte . Exposure Control 6.1 External Exposure Control Audits of the radiological controls program are currently being conducted on a monthly basis by corporate health physics staf The audit frequency during the outage is weekly, and is expected to increase to a near continuous basis in the near future. The audit h reports for the period July 1986 to July 1987 were reviewed, and an i improvement in.the quality was noted. The findings of the audits are utilized to isolate program weaknesses, thereby indicating possible program improvements. Supervisors in charge of areas involved in i

audit findings are required to respond to the findings and to propose a resolution to the proble The audits play an important role in i maintaining a quality program, and it is recommended that the current and proposed frequencies be maintained while increasing the depth of

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f, . . 9 the reviews to emphasize the root causes of observed deficiencies and thus suggest means for program improvemen Past. inspections had identified the area of procedure quality as a program. weaknes Some of the. procedures were found to contain technical inaccuracies, and other procedures were not well written nor easy to understand. A committee has been formed to review station procedures with a view to improving their quality. -The committee members include both corporate and station staff. The committee has revised some of the procedures. Review of important procedures that have been revised recently show that the quality has improved substantially. The revised procedures are more complete and include clear definitions and instructions. This trend toward improved procedures should continue and the committee to review and

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revise procedures should be established as a permanent body to review all new procedures in depth to ensure consistency, technical content, and clarit The findings of the corporate auditors should be-incorporated into procedure revision The adequacy of posting of radiation and contamination areas wa inspected by walk-throughs of the various areas of the plant. All areas were found-to be adequately posted. An addition'to the standard postings is the ALARA posting. This takes two forms: areas posted as low background and therefore suitable for assembly during job related preparations, and areas posted as above average background and therefore not to be occupied for more than the minimum l j

time consistent with completion of the task involving such areas, a These postings are a good idea and are-quite useful for people walking through the RCA without survey instrument The RWP. system was reviewed and was found to be acceptabl Control 1 over access to high radiation areas has been substantially improved by introducing an attachment to the RWP called the high radiation ]

area access card. The card is issued by the dosimetry section and is I required for entry into high radiation areas. Approval by the J radiation protection supervisor or his designee is required for entry using these card A checklist has also been added to the RWP for high radiation area access. The checklist is intended for use by HP technicians and is used as a reminder to ensure that all important aspects of a high radiation area entry are considered by the technician. The access control procedure has been revised recently, and important concepts such as continuous HP coverage and remote monitoring are explained much more clearly than has been the case in previous versions of the' procedure. A new steam generator control area has been added in preparation for the current outage. This area 1 is to be used for control of workers entering on steam generator l related RWPs. The area is equipped with a set of TV monitors, one for each generator. Each monitor is to be handled by a technician assigned the responsibility of monitoring work on the respective generator. A supervisor monitors all work in the generators on his own TV monitor syste ;

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, 10 The dosimeter of record is the Teledyne thermoluminescent' dosimeter (TLD). Review of the dosimetry system and the methods used.for dose assessment based on dosimeter. readings indicated that the system'i adequate for monitoring personnel on site. The TLD~ system is used for monitoring photon, beta, and neutron radiations. The dosimetry operation is accredited by'NVLAP (National Voluntary Laboratory Accreditation Program). Review. of dose reporting based on the TLD system revealed that th'e licensee is not reporting whole body dose at-300 mg/cm2, as required by NRC Form-5, if eye protection is not use Furthermore, the TLD dosimeter does not provide for dose measurements under a shield of 300 mg/cmr thickness. The licensee stated that they are meeting NRC Form-5 requirements by performing surveys with survey instruments equipped with 300 mg/cm2 filters placed in front of the instrument's open window. If there is. evidence of radiation penetrating this filter but.not the closed window, this is taken as

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an indication that eye exposure may be a limiting consideration and'

eye protection is prescribe By following this procedure in every

. situation in which eye exposure may be limiting, the licensee considers that the requirements of NRC Form-5 are met. A brief review of the dosimetry operation was conducted as part of this inspection. Although this review was not adequate to inspect the details of the operation, the overall assessment is that'the system is adequate ror performing its personnel monitoring function. The staff in charge of the system was also found to be fully aware of the capabilities and limitations of'their system, as well as the state of personnel dosimetry technology in genera .2 Internal Exposure Control 10 CFR 20.103 requires control of exposure to airborne concentrations of radioactive materials, NRC Regulatory Guides 8.9, " Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Progrr.m,

"and 8.26, " Applications of Bioassay for Fission and Activation Products," provide guidance for an acceptable program of bioassay measurements to determine an individual's exposure to concentrations of radioactive materia During Inspection No. 50-213/87-16, the licensee's capability to make in vivo measurements of radioactive material using whole body counting was assessed. During this appraisal, the bases for the licensee's bioassay program and application, of the licensee's radiation protection program to control of internal exposures were reviewe Licensee performance was evaluated by examination of procedures, calculations, radiation work permits and other documents, interviews of licensee and contractor personnel and observation of radiation protection practices during plant tour The licensee's corporate health physics organization provided the bases for a bioassay monitoring program, (whole body counts, urinalysis and/or fecal analysis) and internal dose commitment

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calculations. consistent with NRC regulatory guidance and industry

.o consensus standards. Standardized Health Physics Procedures (SHPP)

were issued for internal exposure control and internal dose calculation and. incorporated into Connecticut Yankee procedures. The -

bases for the SHPP were reviewed and found to be technically correct and adequate. Review of Connecticut Yankee procedures showed the procedure to be consistent with the SHPP. Implementation.of the-procedures in assessment of three inhalation exposures in September

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1985 was reviewed and determined to be adequat .The licensee extensively decontaminated plant areas prior to the outage to reduce areas of potential airborne radioactivity to a minimu Contamination control procedures, (e.g. control point personnel " frisking," auxiliary ventilation control, step-off pad usage, area / work airborne radioactivity surv'eillance, etc.) were reviewed and determined to be adequate for the levels of. radioactive contamination present. The 1.icensee was. implementing an adequate and effective internal exposure control program for the outag .3- Respiratory Protection An. acceptable respiratory protection program is established in NRC Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," and detailed in NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials. A review of the following aspects of the licensee's respiratory protection program was completed:

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policies and procedures; selection of equipment; training and instruction of users; fitting, use,-cleaning, storage, inspection, quality assurance and maintenance of equipment;

. work area ~ surveillance; user medical surveillance; and respirator-inventory contro Licensee performance in these areas was evaluated by review of procedures, radiation work permits and other documents, discussions with licensee and contractor personnel and observations of respiratory protection practices during plant tour The Health Physics Supervisor has overall responsibility for the administration of the respiratory protection program. Physical qualification of users is accomplished by a medical questionnaire, spirometer test and an evaluation by the licensee's medical depart-ment. The Supervisor of Health Physics and Chemistry Training directs respirator user training. Personnel having an identified need for respiratory protection receive training, fit testing, a

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., 12 whole body count and medical evaluation prior to qualification as respirator user Respirator use policies were clear. All radio-logical work involving respiratory protection is governed by a Radiation Work Permit (RWP). Prior to issuance of the RWP, health physics personnel evaluate the actual and potential airborne radio-activity present, consider other factors _(including possible oxygen deficiency in the work area), determine the necessary protection factors for the equipment to be used and specify the type of respirator on the RWP. Review of this process showed the health i'

physics personnel to be knowledgeable concerning respiratory protection practices and representative RWPs to be adequate in the specification of required respiratory protection equipment. ALARA review frequently specified engineered ventilation control An issue point monitor verifies that a user will be working under a RWP requiring a respirator, the user is clean shaven and qualified for the respirator; issues the appropriate respirator; and records the respirator's identification number on a respirator issue record  ;

form. Users must return respirators to controlled proper receptacles j by the end of the assigned shift. Failure to do so results in a 4 Radiological Deficiency Repor The licensee maintained adequate inventory control of respirators by this proces I Respirator users perform qualitative face seal tests prior to entry )

into the airborne area. Discussions with respirator users showed a clear understanding of the need for the tests had been provided in the licensee's training progra )

After use, the respirator it disassembled, cleaned, disinfected, j reassembled, repaired if necessary and returned to inventory 1 following testing. Discussions with contracted technicians operating the licensee's respirator cleaning and repair trailer facility showed that special repair training had been completed by those technician ,

The technicians were knowledgeable in their repair and inspection i duties. Each respirator could be tracked through the licensee's maintenance process indicating adequate control of respirator inventory was being maintained throughou Self-contained breathing apparatus is controlled separately under the licensee's emergency planning. Inventory control, testing and main-tenance activities are well-controlled for these devices. Supplied airline equipment (including airline hoods used in Steam Generator  ;

work) are separately issued and controlled. Noteworthy is the 1 licensee's single use (disposal versus decontamination) of airline

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hoods in Steam Generator wor Review of respiratory protection equipment inventories on hand showed that the equipment had received approval under the NIOSH or Bureau of Mines program The licensee's respiratory protection program was adequate and was being imple.nented appropriately during the outag _ _ - _ _ _ _ _ _ _ _ -

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e 4, 13 6.4 Surveillance Program-6. Procedures and Basis

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The basis-and direction of the surveillance; activities are specified, L or implied in: Procedure RAP _6.2-13, " Radiological Surveys". This l procedure' defines surveillance frequencies, methods, and types of surveillance as well as the-scope of each survey.

L-6. Types-The licensee _has made provisions for radiation, contamination, and airborne surveillance activities at specified frequencies and locations. .These. provisions appeared-to contain adequate direction-for each type of survey based upon working conditions and radiation ha::ards .

'6. Instrument Suitability and Use The numbers and types of various portable, fixed, and semi-fixed instrumentation was reviewed. Based on this review and discussions with licensee personnel, the-1icensee appears to have both an

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adequate complement as well as sufficient numbers of instrumentation to support surveillance activitie Portable survey instruments are-source checked after calibration and prior to use. The licensee appears to have adequate instrument control. Amounts of survey supplies, such as survey forms, appeared to be in adequate suppl . -Radioactive Waste. Management System 7.1 Program Responsibility While the responsibility for all aspects of Radioactive Waste Management are not assigned to a single authority, the licensee has centralized certain elements of the program in various department For example;

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monitors performance of ion exchange equipment and determines the need for changeout, samples and analyses gaseous and liquid effluents to provide

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set release rates prior to the release out the stac Operations -

Performs all systems lineups necessary to transfer materials to the waste solidification area or to the plant release stack.

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, 14 Health Physics - Under the direction of the Radioactive Materials Handling Section, performs the packaging and shipment of radioactive waste. This section is also respon-sible for station decontamination and laundry l service I The responsibilities of the department are described in a broad sense by Administrative Procedure ADM 1.1-41. The interface requirements between the functional departments is not described by procedure and coordination between departments is usually performed on an as needed bases. This process appears to work to assure conformance with current regulatory requirements affecting radioactive waste managemen .2 Liquid Wastes The liquid waste system consists of the boron recovery system and the q liquid radioactive waste disposal system. Based on a review of '

procedures and discussions with licensee personnel the inspector determined that the systems possess adequate flexibility to allow for alternate methods of processing liquid radioactive waste in order to meet Technical Specification requirements. The licensee's chemistry I department monitors system performance and attempts to match ion exchange resins to the types of radioactive waste in the system Additional temporary liquid radioactive waste processing capacity is

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currently being added to the liquid radioactive waste system. This system consists of a series of skid mounted demineralizer The temporary system will be operated by the system vendor personnel.

l The changes required for installation of the tempora y system have l undergone a 10 CFR 50.59 review. This review included radiation l safety and ALARA concerns as well as environmental concerns. In I

addition, the vendor operating procedures have been reviewed by the licensee's plant operations review committee (PORC).

The liquid radioactive waste system procedures include release rates, alarm set points, laboratory analysis results, Technical Specification compliance, valve line ups, and appropriate review and approva .3 Gaseous Wastes The gaseous waste system consists of the gaseous waste treatment system: waste gas compressors; waste gas surge tank, and waste gas decay tanks. Discussions with licensee personnel, including demonstrations of actual operating procedures, indicated that gaseous radioactive waste processing and releases are performed in accordance i with approved procedures for assuring that activities involving the j transfer and discharge of gaseous effluents are in compliance with '

Technical Specification requirement i

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- Effluent / Process Instrumentation The inspector reviewed the licensee's program for tne maintenance and calibration of effluent and process radiation monitors. A routine

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, radiation monitor calibration program has been established in written procedure This includes both chemistry and I&C procedures. Actual

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source geometries are used for calibrations with statistical curve fits of the calibration data. The inspector noted that the I&C procedures set the lower energy threshold of the radioactive liquid waste effluent monitor at 100 kev. The chemistry department performs H a source check of this monitor with an Am-241 source in order to determine the response to the 59.5 kev Am-241 gamma radiation. The counts from the Am-241 source check are recorded on the radiation monitor calibration form, but there is no acceptance criteri > c Chemistry department personnel stated the Am-241 source check is

/ performed in order to verify that the monitor will respond to Xe-133 in liquid radioactive wast Xe-133 has a gamma energy of 81 ke The inspector discussed with the licensee the apparent discrepancy between I&C setting the lower energy threshold at 100 kev and the '

chemistry department counting an Am-241 source with a 59.5 kev gamma ray energy. The licensee stated that this area would be reviewed and a lower energy threshold established so that Xe-133 in liquid y radioactive waste would be detected and monitored. The inspector ,'

stated that this area would be reviewed during a subsequent inspectio (213/87-17-01).

i ALARA Program ,1

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l A review of the area of ALARA revealcd considerable improvements since the last outage. The process of setting man-rem goals has been changed such that the goals now reflect realistic expectations. The process of goal setting has also been changed to include both the site and the corporate staf Because of the more realistic goals now being used, management is seriously holding the job supervisors accountable for their worker's exposures. Job planning has also improved considerably. The lead time for this planning has been extended, and the engineers in charge of outage projects are_no'w expected to perform on-site inspections of the systems (

, involved during the outage prior to the outage in which the work is to be

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done, as well as'at. later times if necessar Site personnel are closely ,

involved in this process, and provide valuable input during the planning staaes. Another important contribution by site health physics staff is publication of a report on the previous (1986) outage. The report provides detailed breakdowns of the man-rems incurred during that outage, descriptions of the jobs performed, and suggestions for improvements in ALARA performance for similar jobs. Overall, there has been a considerable improvement in outage plannin i

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At the time of this inspection, the outage was just starting. Jind it was therefore not possible to assess the success of %hese measures. 'However, all indications were that the efforts are well directed and rhocid 1 succee The only uncertain aspect of this improvement was that the measures taken to improve ALARA performanc'c did rst appear to have been incorporated as formal requirements to be implemert'ed 1n future. outage The licensee stated that site management is re'sponsible for Erhuring that all measures to improve ALARA performance irtil be carried out during this and future outages. Another area of conce n was that there has t<een -

apparently no change in the manner in which contractors are to be held responsible for the numbers of workers assigned to jobs anc the exposures  ;

accumulated by those workers. Discussions with the licer.see indicated '

that several ideas were considered to tie centractar. contracts to exposure performance. However, difficulties were encountered in accomplishing this -

measure. The licensee indicated, howeveri, that site management will monitor contractor exposures closely and 16)1 take appropriate action in case these exposures appear to be in dangar Hof becoming excessiv /

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area, All of the above areas appeared to be adequate. Th ..

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during the last appraisal, has been relocated and expanded and consists of a large room with an adjacent room iur instrument decontaminatio The ins'trument calibration facility is used fori, calibrating both radiatiori monitoring instruments and air samplinj equipmen .2 Equipment The inspector reviewed the licensee's equipment wit'n respect to types, numbers, ranges, and rans{tivity. This included portable equipment such as radiation survey meters and air samplers, and fixed and semi-fixed equipment such.as counting room equipment, area monitors, and portal monitors. Ite licensee controls health physics instrumentation through the use of a computer based " instrument calibration and inventory list' which monitors the operational status of the instrumentation. This list is updated 9 a morathly basi Both instrument calibraticas and air sampling equipment calibrations are traceable to NBS. Based on the above review, health physics equipment appears to be adequat l .-~3 .~ . . .

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