IR 05000219/1990002
| ML20012B782 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/06/1990 |
| From: | Dragoun T, Oconnell P, Sherbini S, Jamie Wang NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012B771 | List: |
| References | |
| 50-219-90-02, 50-219-90-2, NUDOCS 9003160268 | |
| Download: ML20012B782 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION I
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REGION-1
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Report'No.
50-219/90-02
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Docket #o'. -50-219-
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License No. DPR-16
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s Licensee: GPU' Nuclear Corporation
P. 0.-Box 388.
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. Forked River, New Jersey
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Facility Name: ' 0yster Creek Nuclear Generating Station
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Inspection At:
Forked River, New Jersey
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Inspection: Conducted: January 29 - February 2, 1990
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~ Inspectors: '
Ne a
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Health Ph
/ date-J. Wanglation, Wasbsicist, ffliclear Reactor r
Regu ington-D..C.
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- 7.. O'Conni11/ Radiat1#n~ 5pecialist, Facilities.
date
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Radiation Mtection Gection
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sfc/90.
5. 5herbini, Senior Radiation Specialist, date Facilities Radiation Protection Section
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Facilities P,@Miation Protectio.SectionI. Dragmin,' ey'ior Radiation 5 ecialist, date
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~'9003160268 900309 Ei
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'PDR ADOCK 05000219 M
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//90 Approved by: /
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W. Pasciak, Chief, facilities Radiation
/ /date Protection Section Inspection Summary:-Inspection on January 29 - February 2, 1990 (Report No.
50-219/90-02)
Areas Inspected: A special, announced, inspection of the status of the
.. radiological. controls program on site and the status of implementation of the
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i plans for improving performance in radiological controls.
Results: Within the scope of this inspection, no violations were identified.
Some concerns regarding implementation of improvements were identified. The main strength observed was that the licensee was able to correctly identify most of-
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the problem areas that have diminished the quality of-performance in radiological controls on site.
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DETAILS
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i 1.0 Personnel Contacted L
l.1 Licensee Personnel
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D. Arback, Manager, Radiological Health
- J. Barton, Deputy Director Oyster Creek
- R. Beck,h,- Manager, Technical SupportManager, Radiological and
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- R. Blouc
- K. Brown, Quality Assurance r
T. Eagan Senior Technician
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R. Farrell, Radiological Engineer
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E. Fitzpatrick -Vice President and Director Oyster Creek
- J. Hildebrand,, Director, Radiological and En,vironmental Controls
-S. Hobson
- R. Holmes,- Radiological Engineer
, Respiratory Protection Supervisor
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R. Hurley Radiological Engineer
- J. Kowalski, Manager, Plant Maintenance Plant Training
'* L. Lammers, Director W. Laffey, Group Radlological Controls Supervisor F. Meyers, Radiological Engineer I&C Technician D. Miller
- W. Quinlan,, Manager, Station. Services
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P. Richie Instrumentation Su>ervisor J. Schmid {, Corporate Health- )hysicist
'D..Shriner, Supervisor, Calibration Laboratory
- M. Slobodien, Director Radiological Controls
- D. Smith Manager, Radlological Controls Field Operations
- J. Solaklewicz, Manager, QA K. Stoltz, Group Radiological Controls Supervisor
- D. Tuttle, Chairman, Radiological controls ' Task force E. Vannortwick, Group Supervisor, Respiratory Protection
- A. Washa, Manager, Radwaste Programs
- K. Wolfe, Manager, Radiological Engineering 1.2 NRC Personnel
- E. Collins, Senior Resident Inspector
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D. Lew, Resident Inspector
- Denotes attendance at the exit meeting.
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2.0 Personnel Selection and Qualification 2.1 Selection Criteria-
. Selection criteria were reviewed for supervisor positions and selected technician positions shown on the " Radiological Controls & Industrial Safety" organization chart dated January 1990 and "GPU Nuclear Corporation Organization Plan" No. 10000-PLN-1000.01 dated November
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1988.
The team found that each position had a job description which included specific training and experience criteria. The criteria were z=
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I appro riate to the responsibilities of the sosition and were used J
durin hiring of personnel.
Each position lad optional selection
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crite la which allowed substitution of experience for a college
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degree.-
Guidance for organizational structure has been provided in NUREG 0761,
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NUREG 0731, and Regulatory Guide 8.8.
The structure at Oyster Creek
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differs from that in the guidance in that the DirectorControls does not report dir Ra
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The site
Radiological Controls (RC) group reports off site to corporate
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management which creates an independence from operating pressures, i
However, this weakens the coordinated approach to on site health
physics (HP) program improvements which requires the aggressive
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support of various on site organizations.
l Most supervisory positions have been reviewed within the past few i
years. Some technician positions have not changed since 1976. The
licensee stated that this is because the technician job descriptions were controlled by labor agreements. The team found that qualification requirements and functional responsibilities for the
Radiolo ical En ineer positions were confusing. There are multiple Radiolo ical En ineer positions with equivalent responsibilities but
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with di ferent raining and experience requirements.
The licensee i
stated that they use this arrangement in order to allow hiring
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flexibility. The inspection team stated that if the site Radiological
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Engineers are to play a key role in providing technical oversight (e.g. audits of site HP programs and to provide leadership for program impro)vements, then the oosition descriptions and technical
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qualification requirements should be clarified and improved.
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licensee stated that this matter would be reviewed.
2.2 Qualification criteria l
The qualifications of RC supervisors and Radiological Engineers were reviewed relative to the requirements stated in their position
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l descriptions. Most met the criteria with some minor exceptions (lack of a few years of experience).
The ins)ection team noted that the-rather than a college degree. personnel aased on years of experienceHowever, the licen licensee frequently selected i
I personnel to earn a degree b funding a major portion of the tuition l
expenses.
The Group Radiolo ical Controls Supervisors (GRCS) must l-pass an oral examination con ucted by RC department managers. An oral o
board was observed by some members of the inspection team and was L
determined to be very effective.
L The team also reviewed the supervisory training )rovided to the l
su ervisors and technical training provided to tie Radirlogical En ineers. Although supervisor. training was adequate,. ttz specialized tr ining for Radiological Engineers was barely adequate at a frequency
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of two days per year. This training may not technically prepare the Radiological Engineers to provide programmatic oversight as discussed l
above or to perform routine assignments such as job ALARA reviews.
l The licensee stated that this matter would be reviewed.
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3.0 Training The training programs for radiation workers and for technicians in the radiological controls section were reviewed. The review showed that all the elements of a com)rehensive training > divided into three levels for the rogram were in place and were being implemented. T1e program may be su)
pur)oses of this discussion:
access and radiation worker training, initial
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tecinician training, and technician retraining.
Access trainint (GET 101) the site
>rotected area. g for all personnel who includes required trainin have unescortet access to It is also required as
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partial training for personnel who inve unescorted access to the
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radiological controls area. The training is a one day review of the basics of radiation and radiation effects as well as some discussion of site
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t specific items including responses to various emergency conditions.
Successful comp,letion of a written examination at the end of the training is required.
Radiation Wothr Training (GET-102) tors in more detail and also includes is an advanced version of GET 101.
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covers basic radiation exposure fac discussion of matters related to gaining access to the radiological
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controls areas dosimetry requirements, contamination controls, regulationsthe different types of po dose andotherinformationneededtoworksafelyintheradiologIcalcontrols,
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area.
Practical factors training is also included.
in this training the worker is shown the practical as ects of work in the radiological con {rols
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area, including such items as si ning in on a work permit meaning of and i
response to various alarms, fris ing, use of protective clothingInation is and j
placement of dosimetry. Successful com)1etion of a written exam required. The licensee stated that wor (ers who had taken a similar course at another facility within 18 months prior to em)1oyment at the site are J
given an abbreviated version of this training. Tle training program at the other facility must have been accredited by the Institute for Nuclear Power 0)erations (INP0? to be accepted as part of this exchange program. The aabreviated version, including practical factors and GET-101 takes about 8
hours to complete, compared to about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the full GET-102 training i
plus the time to complete GET-101.
Annual retraininf and consists of a review of the material covered in theThe retraining is required for both GET-101 and GET-102.
material is brie initial training with emphasis on any changes during the intervening both training sessions.pletion of a written examination is required forThe retraining Successful com period.
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hours, including practical factors.
it takes about 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> if the workers
are to maintain respirator qualification.
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Training for radiological controls technicians is divided into two programs one for technicians to be trained for work in the Radiological Health (kH) section and one for technicians in the Radiological Controls field Operations (RCf0) section.
Entry level RH technicians are given about 4 weeks of training consisting partly of the basics of radiation theory and radiological controls practices relevant to their work such as survey of equipment and contamination control. Theremalnderofthetrainingconsistsin instruction in the operation of the various equipment they will be working on, such as the whole body counter and the respirator fit facility. At the
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and after successful completion of a written end of this training,ical factors, hnician examination and pract the technician is classified as a
" qualified * radiological health tec Admission to this program
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requires a high school degree and successful completion of a screening examination. This examination tests the candidate on knowledge in basic subjects such as high school mathematics and science. The licensee stated that this program is not used frequently because the staff in the section is stable and there has not been a need recently to qualify entry level technicians.
The training program for entry level RCf0 technicians involves a six month course that is split equally between classroom training and practical factors. The practical factors are conducted in the plant under the supervision of a senior technician or supervisor.
Graduating from this course requires successful completion of a written examination as well as an oral board examination.
The technician is then classified as a Step 1, degree and successful completion of a screening examination. gh school or Junior technician. Admission to the program requires a hi The licensee stated that they graduated approximately 40 technicians from this training program since 1980.
The retraining programs for the RH and RCf0 technicians are different.
RH each session technicians get about 4 - 5 cyclic training sessions per year usually lasting less than one day.
Thesesessionscovermainlyareviewof basic radiation theory. RCf0 technician cyclic training is organized on a 7-week cycle, with each training session lasting approximately 3 days giving a total of about 18-20 days of cyclic training per year. Aqulzis given at the end of the training aeriod, but there is no official requirement to pass that quiz. Tie licensee stated that the quizzes are used for evaluating the etfectiveness of the training but the supervisors of those technicians who do not do well are notified of the results.
Contractor technicians are given a screening examination before they are hired to test their knowledge of basic health physics and are then given two weeks of site specific health physics training.
dontractortechnicians on long term assignment to the site receive cyclic training only if they are on shift work, otherwise they do not receive such training, i
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There is no required cyclic training program for Group Radiological Controls Supervisors (GRCS). The licensee stated that the GRCSs attend cyclic training with their shift of technicians.
All Qualified (Radiological Health) and Senior technicians and GRCSs must
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requalify for their positions once every two years.
Requalification involves successful completion of a written examination and an oral board.
A review of the training program showed that all the elements of the program were being implemented as required. However, some areas for improvement were identified:
. The requalification examinations givw to the senior technicians are heavily oriented toward basic health pnysics theory. The examinations provide little testing of the technician's awareness of the latest developments in techniques and procedures on site, changes in site systems and equipment, and developments in the industry that affect radiological controls practice.
The licensee stated that testing in these areas is done mainly during the oral boards and that the written examination was only one of three testing modules that lead to requalification the other two being the oral boards and practical H
factors. ThelIcenseealsostatedthatitwouldbeverytime
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consuming to grade examinations that contained essay type answers.
The current examinations are of the multiple choice type.
. The screening examinations for the contractor health physics technicians suffer from the same weaknesses as those cited above for the requalification examinations. The licensee stated that the technicians are also screened during review and verification of their resumes and during interviews.
. The cyclic training for the RCf0 technicians does not present and discuss changes in site procedures, the reasons for these changes, incidents on site industry occurrences, industry develo)ments, regulatory changes, and concerns { and improvements in teciniques in t field.
The licensee stated tha this material is presented to the technicians in the form of documents that are assigned to them as required reading. The system of required reading is based on the technician reading the required material and signing off that the material has been read.
j The licensee stated that they are aware of the above weaknesses and have already taken steps to correct some of them, for example, a new set of examination questions is being developed that changes the orientation of the examinations somewhat toward more applied health physics material.
These questions will be incorporated into a question data bank to be used in future examinations.
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The licensee is also in the process of implementing other measures to improve the quality of training. These include the following:
. A one-day radiological controls training program for managers and supervisors has been developed and is being implemented. The course is introduced by the Vice President and Director, Oyster Creek, either in person or by way of a video recording. The introduction lasts about one hour and presents statistics that show the performance of Oyster Creek relative to other licensees in the area of radiological controls.
Emphasis is placed on the idea that the radiological controls problems at the site are not due to performance deficiencies of the Radiological Controls Department but that they are due to.
deficiencies in all departments on site. The presentation makes clear that improvements in radiological controls depend on improvements in the performance of all departments. The course itself discusses ways in which supervisors may improve their control over radiological factors in the jobs they supervise, such as pre job plannina preparation of workers for the 90b, ensuring availability of, tools and materials, cooperation with radlological controls technicians and similar topics. Allsitemanagersandsupervisorsarescheduledto take this course. The licensee stated that refresher courses may be offered on an annual basis. A review of the video tape introduction to the course showed that the statistics showing performance problem areas were quite clear and effective.
The emphasis on good radiological performance by all departments was also clear.
However there was an insufficient emphasis on the idea of accountability and, the manner in which this accountability would be monitored and enforced.
. Advanced radiation worker training (GET-103) is to be started early this year. This course is designed for workers who are to work in high radiation areas, high contamination areas, high airborne radioactivity areas, or on jobs that involve opening of highly contaminated systems. Selection of workers to attend this training is to be made by the worker's supervisors on an as needed basis.
Training will am lify and extend the material presented in radiation and will include 2 days of classroom GET-102) Ions and one day of practical factors.
worker training discuss The presentations an oractical factors will include material not covered in the standard GET including wearing protective clothing and respirators while performing certain jobs, simulation of surveys in non-uniform fields using radio controlled survey instruments, opening systems that contain water to simulate work on such systems and spills, and the use of an environmental chamber that will simulate the high temperature and humidity conditions that are encountered on some ;obs on site.
. Other new training is being offered to heighten the awareness of
, personnel to radiological conditions at the work site and to sharpen their ability to identify problems when they occur, or to identify poor practices during observation of ongoing jobs.
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A review of the recent history of events of radiological significance at the site shows that many of the events were precipitated by workers not or good adhering to the requirements of the work permits, the procedures radiological cractices. Personsinvolvedintheseincidentsincludedboth radiation workers as well as radiological controls technicians and the deficienciesidentifiedinconnectionwiththeseincidentsincludedsuch items as failing to wear the required dosimetry, working in unsurveyed areas, entering locked high radiation areas without the required equipment, poor quality radiation surveys,iation areas under positive control,and failing to adhere to the for maintaining locked high rad in addition, some jobs were completed without incident but cost more radiation exposure than they should have. Possible causes for this include poor trainina, poorly qualified workers and technicians, and lack of insistence by all Tevels of management on adherence to all requirements for work in the radiological controls area, that is, weak accountability for the proper completion of the job.
Elements of all of these factors probably contributed to the various incidents and to the unnecessarily high exposure clearly addressed in the, only the training issue appears to have beenplans to improve r jobs observed. However plans for its improvement are already being implemented. The newly added training courses should enhance awareness and understanding of radiological considerations. However, the new courses do not affect the manner in which most of the existing courses are being offered, and these may also need closer attention to ensure that they perfcrm their intended functions.
the Inspection Team did not identify clearly defined items in the Also,for Excellence to directly address the possible problem of management Plan and worker accountability.
3.0 Instrumentation and Counting Room Operations The ty)es, quantities, methods of calibration and accountability of survey and otler portable and semi-portable radiation measuring instruments were reviewed during this inspection. Also reviewed were the equipment and operation of the radioactive sample counting room. Operation of the counting room is under control of the RCF0, and repair and calibration of the instruments is the responsibility of the Instrument and Control (l&C)
facility, which is part of the Radiological Health section. The counting room is normally operated by a RCF0 technician under the supervision of a GRCS.
In addition a radiological engineer is assigned the responsibility of providing technical guidance for counting room operations. The counting room is equipped with two germanium gamma spectrometers with a common and two alpha detectors. The computer system, two beta / gamma detectors,ional equipment is planned to licensee stated that the purchase of addit help minimize delays in counting samples, particularly during outages when the number of samples taken increases substantially.
Daily quality control in the counting room includes source checks, background checks, and calculation of minimum detectable activities. An area adjacent to the counting room is provided for counting smears.
Similar areas are also provided throughout the plant to allow field checking of samples prior to
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sending them to the counting room for analysis. This provides an early warning in case the sample contains activity that exceeds an action level.
Some of these areas are provided with lead shielding to provide a sufficiently low background, usually less than 300 counts per minute.
Repair and calibration of portable instruments is done in the I&C shop, which is part of the Radiological Health section. The repair and calibration work is done by five permanent technicians who are su ervised by a group supervisor. The technicians' qualifications are maini in the field of electronics but they are trained in radiological control by the licensee, and also by vendors of some of the detection systems used on site. Accountability for the calibration of instruments is maintained by the I&C group via a computerized system that flags detectors that are due for calibration. A list of these instruments is sent to the RCfD so that the instruments may be pulled from field use and sent for calibration.
Accountability for the instruments between calibrations is the the access control points to the Radiological Controls Areas (gged in at Instruments are logged out and lo responsibility of the RCf0.
RCA. The instruments are also checked daily by the RCf0 using a check sourc)e to ensure proper function, and the checks are recorded in the instrument use logs.
A review of the oneration of the count room and the I&C shop indicated that the system used f' r analysis of samples and for providing calibrated o
radiation measuring instruments for field use appeared to be well organized and the staff appeared to be qualified for their tasks in that system.
A review of selected calibration records and log books also showed that proper documentation was maintained and that calibrations were current.
However, some areas for improvement were identified:
. There is insufficient ongoing technical oversight provided to the instrumentation area. This oversight is needed to ensure proper selection and use of detection instruments and also proper methods of calibration, as well as to oversee a quality control program on the instruments. This includes designing suitable programs for the different types of instruments as well as review of the results of that program to identify problem areas.
. The technical bases for the various practices in the area of instrumentation are not maintained by the site staff, and are not generally known by that staff.
Examples include the reasons for the manner in which neutron instruments are calibrated, the decision not to use a scatter calibration factor for the site neutron calibration source, and the adequacy of using a release limit of 100 counts per minute above background on a pancake probe to ensure meeting the minimum requirements for release of materials from the Radiological Controls Area (RCA?. Although some of these concerns were addressed by the corporate staf#, the site staff did not possess this knowledge.
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4.0 Internal Exposure Control The team reviewed the following areas of the licensee's program to evaluate and minimize internal exposures to radioactive material.
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Training and Qualification
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Respiratory Protection Program Bioassay Program Engineering Controls 4.1 Trainina and Qualification Prior to being issued respiratory protection egs1pment individuals are
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given respiratory protection training. This training consists of a
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four hour lecture followed by an examination and hands on practice using the eautpment. The team reviewed the lesson plans for this training and several examinations and noted.that the scope of the initial training was adequate. The team reviewed the qualification cards and work history summaries of the individuals providing the training. The training personnel were qualified in this area.
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Respiratory )rotection equipment is issued from the Respirator acility. The Respirator Maintenance Facility is staffed Maintenance r
with a Respirator Maintenance Supervisor (RMS) and four Respirator Maintenance Technicians (RMTs)tection Equipment" specifies the Procedure A100-ADM 4020.02, " Issue
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and Control of Respiratory Pro requirements for an individual to be issued respiratory protection
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equipment.
These requirements include ensuring that the individual
has a current: whole body count, physical, fit test, and training.
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The team reviewed the licensee's program for ensuring that only (
qualified individuals are issued respiratory protection eculpment.
l The licensee's program includes having a RMT enter the incividual's name and type of res)iratory protection device to be issued into a
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I computer program. T1e computer is set up to issue a warning statement
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if the individual does not have current qualifications or if the type or size of respiratory protection equipment is incorrect. A print out l
of this information is available to the RMT in case of a computer failure. The team reviewed several records and verified that only qualified individuals were issued respiratory protection devices and
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that the proper devices were issued.
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l The team reviewed the qualifications and training of the RMS and the l
RMTs.
Procedure A100-ADM 4020.08 " Respirator Maintenance Technician l
Qualification" delineates the training program which the RMTs are training, classroom site training,g program consists of vendorand practical fact required to complete. The trainin The team reviewed the training records of the RMTs and noted that the training program had been completed by the RMTs. The following areas for improvement were noted by the team:
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. The current RMS has not completed the RMT training program.
Discussions with the RMS indicated that additional training of the RMS and enhanced licensee supervision of this area is i
warranted until the RMS is fully qualified.
The licensee stated they have temporarily assigned the task of providing oversight of this area to the individual who previously was the RMS. However, the team noted that although the current RMS has been in this position since last summer, the licensee did not assign the
previous RMS the task of providing this full time supervision
until mid January. The licensee stated that the previous RMS
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will continue to provide supervisory oversight of this area until i
the current RMS is fully qualified. This item will be reviewed during a future inspection.
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. Discussions with RMTs and both the current and previous RMS indicated that additional training was needed in the area of ensuring that the air flow for the powered air purifying i
respirators (PAPR)intenance of Respiratory Protection Equipment" was adequate. Procedure A100 ADM-4020.03,
" Inspection and Ma requires that the PAPR be tested to ensure that the air flow rate
is greater than 4 cfm. However, the gauge on the PAPR flow'
tester did not have units of cfm. Discussions with the RMTs and
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RMS indicated that either they were reading the PAPR flow tester
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incorrectly or they did not know how to properly read the flow tester. The licensee stated that they will review the proper method for reading the flow tester with applicable personnel and i
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L the )rocedure will be upgraded to specify the proper way to read
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the )APR flow tester.
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. The team noted that several individuals in the respirator maintenance facility stated that they are required to D0P test charcoal filters prior to issue. Other cognizant individuals in the respirator maintenance facility stated that they do not D0P
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L test charcoal filters. The licensee reviewed this apparent
discrepancy and determined that several years ago,but currentlyas part of
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study they had D0P tested their charcoal filters thefIltersarenotrequiredtobeD0Ptested. All individuals in the respirator maintenance facility were not aware that DOP i
l-testing was not to be done on the charcoal filters.
The licensee then disposed of the charcoal filters which had been DOP tested.
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. The team noted that a prerequisite to Procedure A100-ADM 4020.05,
" Respirator Filter Testing"ination less than 100 dpmrequires that filters be
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This requirement was not consistent with Procedure /100 cm^2.
found to have alpha contam A100-ADM 1020.03, " Radiological Survey of Respiratory Protection
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Equipment" which states that alpha surveys do not have to be taken if the beta-gamma survey result is below a certain value.
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Cognizant supervisors, including the Respiratory Protection L
Supervisor, were not aware of the discrepancy between the two procedures.
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. The team noted that many respirators were stored in large buckets both prior to and after cleaning.
Respirators that had been decontaminated and begged were stored in cubicles, often in such a manner that adjacent equipment could distort the sealing J
surface of the respirator.
after cleaning the respirators, the licensee does Considering that,k test as recommended in Section 10.2 of NUREG 0041,
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not conduct a lea
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" Manual of Respiratory Protection Against Airborne Radioactive
Materials", an improvement should be made in the manner in which the
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licensee stores respirators.
I These examples indicate that enhanced supervisory oversight to review the technical aspects of this program is needed in this area.
5.2 Respiratory Protection Program The team reviewed the licensee's policy statement regarding the use of
respiratory protection equipment. The policy statement was
comprehensive and was issued by a sufficiently high level of
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management to ensure that it's provisions were adequately enforced.
l The responsibility for the respiratory protection 3rogram is assigned
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to the Respiratory Protection Supervisor (RPS). T1e RPS is
i responsible for the res)iratory protection programs at this facility and two other units. Tie RPS stated that he tries to visit on-site twice a month for a-total of 4 to 6 days on-site each month.. The RPS
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approves all procedures, programs, and directives rel& ting to
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respiratory protection.
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A Radiological Engineer at the facility has been designated as the site representative for respiratory protection. This individual is
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responsible for the day to day implementation of the respiratory L
protection program.
On a quarterly basis, the Radiological Engineer selects ten
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individuals for whole body counting. The results of these whole body
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counts are used to evaluate the effectiveness of both the air sam)1ing program and the respiratory 3rotection program. The team noted t1at the criteria for selecting tie ten individuals is such that only individuals who had been exposed to the maximum permissible concentration of airborne radioactivity for less than two hours in any day are selected. An evaluation is not conducted for those
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individuals who had been exposed to higher levels of airborne radioactivity. An improvement could be made in evaluating the effectiveness of the respiratory protection program by evaluating the i
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protection devices and were in areas with higher levels of airborne radioactivity.
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j 5.3 Bioassay Program
The team toured the licensee's whole body counting facility. The licensee's whole body counting equipment include two whole body counters (WBC)the total activity present in the individual beingThe first WBC i
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and determine counted. The other counter is a bed ty conduct follow up counts when required.pe counter and is used toThe bed type*
be used to perform thyroid counts. The licensee has established
procedures requiring whole body counts for initial entry into the
radiological controlled area, at periodic intervals i
suspected internal exposures to radioactive material.and following
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The team reviewed the licensee's method of evaluating individual exposure to concentrations of airborne radioactivity based on WBC
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results. Although the licensee's method is not proceduralized, a Radiological Engineer uses an approved engineering calculation to conduct this evaluation. The licensee utilizes generally accepted
methodology in performing this evaluation. The team reviewed WBC data and found no instances of regulatory limits being exceeded.
The team reviewed the licensee's quality assurance (QA) data for the WBC. The QA program involves conducting a source check every four
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hours for the quick count WBC and a source check arior to use for the bed counter. The licensee also conducts a daily sackground check, a weekly cali' ration check, and a semiannual calibration of the WBC.
u The team identified the following areas for improvement:
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. The licensee has not established control charts for the WBC. The cognizant engineer demonstrated that the com) uter software for
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the WBC is capable of generating printouts tiat approximate
control charts.
However, these printouts are not routinely reviewed by cognizant personnel to identify adverse trends.
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example, the team reviewed a printout of the Co-60 check source l
count data. This printout indicated that either the average
activity of the check source was incorrect (the cognizant engineer stated that the software does not decay correct the check source)l charts would be useful in identifying theseor that the WBC Proper contro trends, f
. The preliminary WBC results for the daily background count indicated the presence of an unidentified peak for several of the
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i background counts. The final WBC result did not identify this
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peak. The team discussed this with the cognizant engineer and the technician operating the WBC. Cognizant licensee personnel'
were not aware as to the origin of the. unidentified peak or why the final WBC report did not include this peak. This indicates that additional training of personnel operating and overseeing the WBC would be appropriate.
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. While the licensee has procedures which address the proper method for conducting excreta analysis the licensee's procedures do not set criteria for when such anal sis needs to be conducted.
5.4 Engineering Controls The scope of the team's review of this area focused on the licensee's program to reduce the total amount-of contaminated areas at the facility. However, during tours of the facility the team did note many examples where appropriate ventilation and containment structures were in place to reduce airborne radioactivity levels.
In 1989 the licensee began an extensive program to reduce the amount of contaminated areas at the facility.
The Station Services Manager is responsible for implementing and tracking the progress of this procram. The licensee estimated that when this program began the facility had 99,000 sq. ft. of contaminated area. At the beginning of 1990 this number was reduced to 79,000 sq. ft. The licensee has set an aggressive goal to reduce this amount to 56 000 sq. ft, by the end of 1990. The licensee's program includes tracking the status of contaminated areas at the facility and routinely resurveying and cleaning areas to ensure that these areas are not recontaminated.
Overall, it appeared that this program was successfully being implemented.
6.0 Control of Locked High Radiation Area Licensee Procedure 9300-ADM-4110.06 ' Control of Locked High Radiation LHRA V specifies the manner In which the licensee controls access to Areas (The licensee's pr gram includes a provision that LHRA keys are LHRA.
assigned only to Radiolo ical Controls Technicians, Key Controllers (whose primary l who have completed training on the licensee's LHb program.atch function at the acility is to be a key custodian) or fire w personne The licensee stated that one of the reasons they have restricted issuing LHRA keys to only these personnel is due to difficulties they have encountered in the past with finding LHRA doors left unsecured. The licensee stated that they have found this approach to be too restrictive and they plan on revising the procedure to allow the issuance of LHRA keys to different personnel with a provision that at least two individuals verify that LHRA doors are secured prior to returning the LHRA key. This item will be reviewed during a future inspection.
The team reviewed LHRA key logs and verified that the licensee accounted for all LHRA keys. The licensee's audits of this program were good.
The audits included a daily audit of the LHRA key log and daily verification that all LHRA doors were secured.
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7.0 ALARA Program The licensee's ALARA program is established and controlled primarily by the corporate office. Documentation )rovided by the licensee indicates there is an active oversight of the ALA M program by top management from the CEO on down. There are high level management committees that provide oversight.
Policies and procedures that implement the program are comprehensive. The corporate Radiological Controls group provides analysis of the site performance and makes improvement recommendations. This high level of visibility has not resulted in any dramatic improvement in performance to date but has clearly resulted in funding of high cost plant improvements such as permanent drywell scaffolding and plans for chemical decontamination of reactor systems. These improvements are expected to show benefit in the long term.
Annual exposure goals are developed for the site along with a target for a long term rolling average. There are pay incentives tied to achieving the goals. The goals for the past few years were usually revised upwards to account for expanded maintenance work. The rolling average goals have also been exceeded and it is unlikely the goal can be achieved in the near future. Department level goals are derived from the station's goal.
Each job reviewed on-site by the Rad Engineers is assigned a goal.
These uses of goal-setting do not appear to have contributed substantially to exposure reductions. The Station Director stated that plant modifications to improve ALARA will cost exposure in the near term and that payback in exposure reductions is expected to begin beyond 1991.
The corporate Radiological Controls group recently completed an excellent analysis of the site's historical exposure data, lutions. identified and quantified sources of dose savings, and proposed specific so The study concluded that low worker productivity combined with hi h source terms (area dose rates) Efforts were initiated to improve prod etivity andwere the major contribut during outages.
included a new mechanical technician qualification program, expanded General Emplokee Trainingf kerformance based contracts for selected outage work, and res ructuring o he Maintenance Department.
Efforts to reduce the source term will include decontamination of reactor recirculation and cleanup systems during the next refueling outage followed by improved condensate filtering to prevent recontamination.
The team reviewed the licensee's " Plan for Excellence in Performance" to determine the extent to which recommendations from the following Radiological Controls documents were incorporated:
-Radiolo ical Improvement Action Item Listing,
-Radiolo ical Improvement Action Plan,
-Technic 1 Development Report (TDR) #941 Rev.1 It was noted that several worthwhile actions regarding work preplanning and productivity improvements had not been included in the Plan for Excellenc..
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In addition, information on prioritization and estimation of expected dose savings were omitted. However, the Station Director recently requested this information from the Radiological Controls group. The licensee stated that the Plan was a "living document" and that appropriate changes would be reviewed.
The team concluded that although the licensee's ALARA program has not been totally effective, management now has clearly identified root causes.
Improved performance by the Construction and Maintenance Department, and in particular, improvement during plant modification work, will be a major contributor to the station's ALARA performance.
Personnel issues such as culture changes and weaknesses resulting from a matrix orgssization are expected to present s,hallenges to management in the effort to achieve an effective ALARA program.
8.0 Exit Meeting 1990.
An exit meeting was held with licensee representatives on February 6, d the The team reviewed the purpose and scope of the inspection and discusse findings in each of the areas inspected.
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