IR 05000254/1980020
| ML19345B192 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/16/1980 |
| From: | Baltzo R, Fisher W, Grant W, Murphy D, Schumacher M, Selby J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19345B187 | List: |
| References | |
| 50-254-80-20, 50-265-80-22, NUDOCS 8011260283 | |
| Download: ML19345B192 (48) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-254/80-20; 50-265/80-22 Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Quad-Cities Nuclear Power Station, Units 1 and 2 Inspection At: Quad-Cities Site, Cordova, IL i
Inspection conducted: May 5-16, 1980 K gr. w n 1..
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Inspectors:
M. C. Schumacher
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W. B. Grant 8'
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J. M. Sel)y D. W 3 u I
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Approved By: WIL.[ise, i
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Radiation Support Jection
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Inspection Summary:
Health Physics Appraisal on May 5-16, 1980 (Reports No. 50-254/80-20; 50-265/80-22 Areas Inspected: Special, announced appraisal of health physics program, including organization, management, training and qualifications, exposure controls, access controls, serveillance, instrumentation, facilities and equipment, radioactive waste management, and accident / recovery capabilities.
The inspection involved 450 inspector-hours on site by five NRC inspectors.
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_Results: Significant health physics program weaknesses were identified in l
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the. areas of training (Sections 3, 5, 9, and 11), exposure control and ALARA
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(Sections 4, 5, and 10), access controls (Section 5 and 6), contamination l
controls (Sections 5, 8, and 9), instrumentation (Sections 7 and 9), and facilities (Section 9). Two apparent items of noncompliance (infractions)
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uncontrolled high radiation area access (Se-tion 5.4);
failure to fellow procedures (Sections 7.3 and 9.8).
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DETAILS
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1.
General The Quad-Cities health physics appraisal program was evaluated during a special appraisal made May 5-16, 1980. The appraisal team consisted of two inspectors from the NRC Region III office and three DOE contractor health physicists.
Site specific orientation for unescorted access was obtained the first morning.
It was followed by a meeting with the plant superintendent
l and set.ior plant management at which time the plans for the appraisal
were discussed. Thereafter, the team had free access to the entire plant subject only to the licensee's normal con?rols for posted and/or locked areas.
Throughout the appraisal, the team emphasized direct interaction with
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workers and direct observation of licensee and contractor work.
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siderable effort was spent on radiation and contamination surveys to independently ascertain plant radiological status and to make compari-sons with licensee measurements. The appraisal extended to evening, midnight, and weekend shifts as well as normal day shifts.
At the start of the appraisal, Unit I was at 90% power and Unit 2 was on approach to power following an extended 22-week outage. Effects of the outage were still evident in housekeeping, which was below the station's normal standard, and in the somewhat depressed morale of the Radiation Chemistry Technicians (RCT's). The appraisal team made significant findings in several areas (Appendix A).
Among the findings were matters that reflected the outage and indicated the need for more emphasis on keeping y with day-to-day housekeeping, waste handling, and contamination ec.. trol. Overall, however, the health physics program observed by the team was basically sound.
Its principal strength was in the generally good quality of Radiation Chemistry (R/C) Department technician and management staffing and of the station management.
2.
Organization and Management 2.1 Description The station organization, including the Radiation Chemistry (R/C)
Department, is shown in Figure 2.1.
The Radiation Protection Manager _(RPM) role at the station is filled by the R/C Supervisor, who reports to the Assistant Superintendent for Administrative and Technical Support (ASAT). This schene is standard throughout Commonwealth Edison Company (CECO). Although the scheme works well at Quad-Cities, the appraisal team believes, in general, that the RPM should report to the highest station level. At Quad-Cities, this direct interaction with the station superinten-dent is assured by the personal style of the incumbents.
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Attual functioning of the R/C Department varied from the depicted organization in that the RCT foremen worked for the lead health physicist or for the lead chemist in dealing with matters in their respective areas of responsibility. This appeared to work well.
Corporate health physics support is currently weak owing to short j
staffing; the expertise, consisting of two professional HP's, is vested in the Technical Services, Nuclear, Department. Support for environmental, radwaste, and radiochemistry is also in this department. There is no line relationahip between station and corporate HP; the latter group provides some guidance and support on generic matters such as contracted external and internal dosi-metry services and in maintenance of the official exposure record system. There is need for additional effort in development of reasonable standardization among the different plants. Significant computer systems support is needed to help the stations with tracking such records as training, medical qualifications, mask fitting, and exposures, particularly during outages. The commendable TI.D-based system for closely following outage exposures (Section 4.2) developed at the station was hamstrung for want of computer system support from the corporate office.
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SUDERINTENDCMT PERSONNEL 0 5 S T. S U P T.
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ADMINISTRATOR OPEPAT!ONS ADMlbl.tSUPPORT MA!NTEMANCE
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2.2 Scope of Responsibilities Scope of responsibilities of the Radiation Protection organization are generally well understood although not particularly well de-
fined in station procedures. Basically, the R/C Department has
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the responsibility to assure that radiation protection standards for workers are being met and that environmental releases meet limits. The R/C Department also carries collateral duties related to shipment of solid radwaste and first aid.
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i Authority of the radiation protection program is not strongly
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j defined and its adequacy depends on the individuals interactiag.
Basically, there is no authority to force adherence to procedures or to stop work, although such requests have been made and honored in the past. Support by station management appears generally ade-quate, although there are indications of problems from time to time i
between R/C personnel and maintenance, particularly the maintenance foremen. RCT's generally believe that maintenance usually prevails in confrontations.
Job descriptions for various categories (chemists, health physicists, foremen, etc.) are not currently documented, except for the RCT's, but responsibilities are generally well understood.
Licensee repre-sentatives have stated that job descriptions as well as other appraisal tools are being developed by corporate management.
The licensee's formal appraisal program is recent in origin and limited in scope.
It includes management but not union (RCT's);
it appears mainly to concern pay raises. As described by several
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individuals, in the past it has not involved face to face discussion
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between individuals and supervisors befitting a good staff develop-ment program. Also, there can be considerable delay between the appraisal and its communication to the employee. Despite these weak-nesses in the formal appraisal program, station managers generally are well aware of the activities, strengths, and weaknesses of employees at least two levels below. Station management stated that appraisal and informal feedback was a continuing process and cited supporting examples. The appraisal team recommends that the formal appraisal program be broadened to include RCT's.
2.3 Communications
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Communications within the department and without appear generally satis fa ctory. RCT's indicated good awareness of work occurring
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in the plant. Some concern may be warranted for interaction between maintenance foremen and the RCT's.
Occasional movement of contaminated equipment to the maintenance shop and the designation by maintenance personnel of contaminated areas without R/C Depart-ment notification was mentioned but not observed by the appraisal team. Also, unlabelled material in plastic bags was observed being
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lef t in an unmarked area at the maintenance shop entrance, presum-ably for contamination survey (Section 5.6).
This area of communica-tions sc9uld be careful reviewed.
A practice of weekly meetings involving the entire R/C Department is generally followed.
Such meetings usually are held in the morning when the midnight and day shift personnel can overlap. The absent shift is informed of significant matters raised at the meeting, according to R/C Department management.
A typed resume of meetings held during the appraisal was posted, a practice not usually followed in the past. Licensee representatives stated that an effort would be made to keep minutes of future meetings.
RCT's interviewed stated that weekly meetings were not held during outages and that communica-tions deteriorated.
The RCT's maintain a log by which information of interest is passed on to succeeding shifts and to supervision.
The log is reviewed daily by foremen and HP's.
The appraisal team's review indicated that the log was not as well kept or as informative as it once was.
2.4 R/C Department Staffing The staff of the R/C Department (approximately 38 including one full-time and one part-time clerk) is about 11% of the total plant staff of approximately 340. Staff quality appears good at all levels; RCT's and foremen appeared competent and well motivated.
However, in common with other CECO plants the plant suffers the problem of technicians unqualified according to ANSI N18.1 some-times manning back-shifts without supervision other than the shift engineer (Section 3.1).
Staffing levels appeared adequate for routine operations. However, staffing needs are suggested by: weaknesses in the RCT and foremen retraining program (Section 3), the continuing (post outage) heavy demand on the R/C staff, the occasional unavailability of RCT's during the appraisal, (Section 6.1), the added work from post TM1-2 demands, the increased attention to low-level waste shipments, and the backlog of significant projects maintained by R/C management.
It was clear to the appraisal team that the foremen need to spend additional time in in plant interaction with the RCT's.
'the need was said to be even greater during outages. Foreman experience is also somewhat wasted in paper work duties, such as instrument file maintenance, supply inventory and order, and used respirator collection.
RCT staffing may be inadequate during high demand periods such as outages.
It has been customary to augment station staff with sig-nificant numbers of contract RCT's.
However, station RCT's appear to resent the presence of contract technicians and the most recent outage was covered by the station staff with the help of an HP, an engineering assistant, and four RCT's from another CECO station.
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The outage was abnormally long (about 22 weeks) and burdensome owing to consecutive long (10 to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) days without a break. Efficiency suffers and the effect hangs over into the post outage period.
Station management indicated that contract RCT's would probably be used in the fall outage, which was also expected to be long.
Several licensee personnel interviewed pointed out a need for more decontamination personnel during the outage. Appraisal team observa-tions of post outage conditions agree with this suggestion.
Perhaps the greatest current staffing need is for a dedicated in-dividutl or small group to work on ALARA engineering.
Significant ALARA work has been done (Section 10) but the 1980 projection of more than 5000 man-rem makes evident the need for greater effort.
The station makes some use of specialists by using EA's (or some-times foremen) for a few particular jobs, most notably tracking of exposures for individuals and for specific jobs. Need for specialists is also recognized by the designation of an "0" man on day shift for operation of the more sophisticated equipment such as atomic absorption (AA) spectrometer and the GeLi spectro-meter. This position is rotated among a group of eight experienced RCT's normally assigned to dayshift. Otherwise, most jobs appear
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to be rotated among the RCT's, with exposure balancing figuring prominently in specific assignments. A significant hiatus can sometimes occur between successive assignments to such duties as mask fitting, whole body counting, and laboratory. Several RCT's interviewed indicated that the variety of assignments is more interesting but admitted that procedures may be forgotten or pro-cedure changes not picked up between assignments. They cited the need for a designated person to go to for help in such matters.
This would appear to be a proper role for a forema- = EA or a more specialized RCT.
Some specialization is seen at the HP leve'.
In addition to unit responsibilities, each HP is given resp".sibilities for specific areas, such as internal exposure (indr. ding respiratory program, whole body counting, air sampling,
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enviromental monitoring, and radwaste.
Backup in all n.as is providea by the lead HP.
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A full-time clerk with more than one year of experience currently works in the department. The position apparently is not a highly rated one in the clerical hierarchy and other department personnel have expressed concern that department will suffer a significant loss of efficiency when the clerk moves to a higher graded position.
The station shares the more general CECO problem of loss of health physicists. An RPM qualified HP with seven years of experience will soon be leaving the station for another utility. M other was said to be looking.
Station management stated that two HP's and an en-vironmental engineer were being hired for the station. Without-8-
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experience, significant training effort will be required to bring
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them "up to speed." Again, dedicated EA's and/or clerical help would permit more efficient use of professional health physicists.
2.5 Audits Formal quality assurance audits are performed by persons who work at the station but who report offsite to the corporate Quality
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Assurance Organization.
In addition, a semiannual audit is per-formed twice yearly by offsite personnel in accordance with Technical Specification 6.1.G.I.b.
Onsite audits and surveillances for 1979 and 1980 and offsite audits for 1978, 1979, and 1980 were reviewed.
There were few findings in the area of health physics. One excep-tion, offsite audit 80-I, on April 10, 1980, noted that scheduled background and standard source counts were being neglected during the outage, owing to frequent use of the machine.
For the most part, onsite QA activities regarding health physics are largely preoccupied with transport of low-level wastes.
The offsite QA aedits provided a reasonable quality assurance review.
However, neither substitutes for the in-depth, independent technical appraisal needed by management to assess the adequacy of the health physics program. The corporate health physicist
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at the exit interview noted that a task force study in progress was reviewing needs in this area.
2.6 Summary Based on the appraisal findings, organization and management of
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the health physics program appears to be acceptable.
However, the appraisal team recommends that consideration be given to strengthen-ing corporate health physics support for the station, to including
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RCT's in a formal appraisal program, and to carefully reviewing R/C
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Department staffing (including decontamination personnel), taking into account the matters noted in Section 2.4.
3.
Selection, Qualifications, and Training 3.1 Selection Selection of RCT applicants is principally in the hands of the R/C Supervisor, who carefully interviews each person bidding on newly posted RCT positions.
In addition to general CECO require-ments of high school diplomas and passing a basic mathematics and science test, the. supervisor looks for additional training and/or experience in radiation protection or related areas. A significant number of RCT's hired at the station have had military nuclear experience. New professional personnel (HP's, chemists)
are hired by the corporate office but are interviewed by the
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station before assignment there. The appraisal team generally
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was impressed with the maturity and competence of R/C Department personnel encountered.
Based on the appraisal findings, this portion of the licensee's program is acceptable.
3.2 Qualifications Supervisors, HP's, chemists, foremen, and engineering assistants in the R/C Department are generally well qualified by training, education, and experience. The R/C Supervisor and two of three HP's with college degrees meet ANSI N18.1 (1971) requirements for Radiation Protection Supervision. The R/C Supervisor and one HP also meet the Regulatory Guide 1.8 requirements for Radiation Protection Manager (RPM); the Lead HP was to meet the RPM requirements by July 1, 1980. The Health Physics group also includes an HP (BS Radiological Health) with two years plant experience, two Engineering Assistants (EA's) with thee and nine years CECO experience, and two foremen with about seven and ten years radiation protection experience. The Lead Chemist has a BS degree and meets the ANSI N18.1 requirement for Radio-chemistry Supervisor. The chemistry group also includes three chemists with BS degrees and seven months to four years experience and a laboratory foreman with ten years experience.
The present RCT group numbers 24 individuals with experience ranging from ten months to more than six years. Fifty percent have over 24 months station experience as RCT's (Table 3.1).
Ten RCT's came on station with relevant prior education or experience, such as in military or medical radiation technology programs.
Table 3.1 RCT Experience (5/1/80)
Experience (months)
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46 67 770 Number of Individuals
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3 Six of the more senior RCT's are assigned to day shift. One RCT (two years or more experience) is assigned permanently to each of the two backshifts. The remaining 16 RCT's rotate (Section 2.4)
to cover days, weekends, and a second position on the backshifts.
The rotation proceeds without regard to RCT experience and can result in RCT's who lack ANSI N18.1 cualifications for responsible
technicians working without quali..cd R/C Department supervision present. The qualification problem results from having a single grade classification for all RCT's regardless of experience or other qualifications.
CECO needs a multigrade RCT structure that makes such distinctions.
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Sased on the appraisal findings, this portion of the licensee's program is acceptable. However, the station should consider a multigrade RCT structure and other means necessary to ensure that unsupervised technicians in responsible positions meet relevant A1SI N18.1 (1971) requirements.
3.3 Training-General The Health Physics Appraisal was conducted at an inopportune time for the Training Department. The Training Supervisor recently had been transferred to this position.
While cooperative, he was unable to provide detailed information on many matters of concern to the appraisal team. Moreover, the RCT instructor was away from the station attending a university course. Opportunities to explore training were thus limited to discussions of general concepts, documents on file, and some instructional details contributed by
& former instructor now reassigned as an Engineering Assistant (EA)
in the R/C Department. Specifically, RCT training information available to the appraisal team was insufficient to permit detailed evaluation of station effort measured in full-time equivalents (FTE)
as an indication of balance and commitment.
The Quad-Cities training facilities are located in a separate building outside of the protected area fence. Eight reactor operator-instructors and one former RCT instructor comprise the faculty. The op.arator-instructors rotate into supervisory operator positions at regular intervals.
By' contrast, the former RCT is permanently assigned to training. He is required to cover a broad spectrum of technical material with only limited assistance and with no opportunity to refresh his plant skills. This is not a desirable situation nd could have a deleterious effect on RCT training.
As part of the review, individual training records, progress reports, and lesson plans kept by the Training Department were examined. Qualification summary records and lesson plans appeared to be incomplete in 20 to 30 percent of the cases, inoicating primarily an overburdened and understaffed clerical function in the department.
3.4 Nuclear General Employee Training (NGET)
Nuclear General Employee Training (NGET) within the preceeding 12 months is required of all unescorted persons entering the plant, including employees, visitors, security personnel, and contractors.
In 1979, approximately 2400 contractor employees were NGET trained. The five-hour course includes general security orientation.
It includes a demonstration of, but not general participation in, the wearing and removal of protective clothing and step-off pad procedure. This was mentioned as a training weakn:ss by many RCT's interviewed. NGET was also weak in the
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treatment of low-level radiation effects, such as cancer, and in making the logical connection between such effects and health physics control practices such as protective clothing, step-off-pads, and respiratory protection. This was in contrast to a forth-right and well developed discussion of prompt high-level exposure effects and related health physics controls such as personal dosimetry, timekeeping, and access restrictions.
Comments made by station personnel on a number of occasions during the appraisal indicated continuing friction between RCT's and production oriented maintenance foremen over implementation of contamination control procedures. These difficulties may be attributable partly to over-looked training opportunities.
The team NGET observer noted that the instruction relied excessively upon the weight of regulatory authority.
In many topics where station procedures were being described, the justification for following pro-cedures is concern for the future health and well-being of the worker.
Although this can be inferred from what was said, this point should be expressed often enough to be clearly understood. Repeated state-ments that the nuclear station carries out procedures because of federal regulations convey the message that the principal concern is the NRC, r.ot the individual. NGET offers an oppe.tunity to motivate new workers toward safe performance and establish a receptive attitude toward nuclear worker skills if motivational concepts are properly addressed by the instructors. An opportunity for reenforcement is also missed by not conducting an examination on completion of the cours" 3.5 RCT Training New RCT's normally are brought into the department via an RCT training course after six to twelve months of power plaat ex-perience. RCT's entering by this route have some orientation in plant operation and systems before entering the 16-week RCT course. Possibly as a consequence, major effort is dire.ced to mathematics, basic science, and health physics related science but not to reactor systems and engineering related topics. The foremen and several more experienced RCT's particularly commented on this as a deficiency in their own training. Systems training, as well as basic science and math is common to operators and could be offered by operator-instructors in trade for RCT-instructor input into training for other personnel. Station HP's contribute to RCT training as circumstances permit but greater use of this resource would also be beneficial.
RCT lesson plans appear to have been originally derived from NUS Nuclear Plant Instruction Guidelines.
It was also evident that many lesson plans had been reworked and abystnted by the instructors to reflect their experience over the y'.3.
As with NGET, the most notable weakness observed religt? tc lou-level exposure, internal emitters, and their rel> t, snthic to ' latent effects such
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as cancer.
Subsequent to the appraisal, a May 1980 draft Regula-
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tory Guide entitled "Information Concerning Risks from Occupational Radiation Exposure" has become available. The appraisal team believes that this document and the recently released BEIR III
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Report may be of considerable assistance in defining the scope and priorities of this topic.
Upon completion of each training module, RCT progress is tested by written and graded examinations. At the end of the classroom sessions, the instructor writes an evaluation of each student.
The final six weeks of the training program are devoted to on-the-job training. Progress is supervised by experienced RCT's.
As each e signed task or topic is completed, it is reviewed and signed off by the foreman.
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Because no RCT training course was underway, the appraisa. team
was unable to directly evaluate the effectiveness of the current program. However, it is worthwhile to mention the observation of several experienced RCT's that recent RCT training courses were significantly superior to the one they received. They also indicated their own need for deeper training in the underlying principles of health physics to reinforce and strengthen the practical experience they have accumulated.
The appraisal team believes this is a proper and desirable subject for RCT retraining.
By contrast with basic RCT training, retraining has been variable in concept and implementation. Before 1978, new laboratory topics and new counting instrument courses were introduced and labelled as retraining and the course was expanded to one week.
However, some RCT's interviewed stated that the 1979 retraining slipped to just three days becta.e the week included a holiday and another full day was devoted ;o first aid training. Even one week of
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retraining, a two percent commitment, is low by industry standards I
and by comparison with operator retraining.
The appraisal team believes that significant improvement should be made in this area.
3.6 C(her Health Physics Training Operator and maintenance staff training does not include informa-tion relating to biological effects and the necessity for control procedures beyond the level of NGET. Despite extensive development of electronics and control instrumentation, the 14-week Equipment Attendant course includes only one day on radiation survey instruments withaut reference to hazards, regula. ions, limits, and control pro xdures. This omission appears to be repeated in Operator A and B iesson plans as well. Maintenance men receive no relevant training until they progress to the Super A two week course. Notwithstanding this singular lack of preparation, stationmen, operators on Rad Waste assignment, and maintenance men are occasionally required to read instruments and control their own exposures during routine work assignments.
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The Training Supervisor and Stationmen Foremen indicated that newly hired stationmen receive no additional instruction related to nuclear phenomena, radiation hazards,'and control procedures than that contained in NGET before their involvement in daily operations and maintenance work. Daily contact with their foremen, and informal on-the-job training explanations (often conducted in haste) do not appear to provide an adequate basis for career work in a technical and possibly hazardous environment.
In the relative absence of supporting conceptional education, stationmen, later to be operators and RCT's, and maintenance men fail to develop con-sistently positive attituaes toward regulations and plant controls.
In several instances training deficiencies appeared to be related to questionable performance.
Although not specifically examined during the appraisal, it is the experience of the appraisal team that similar problems can arise with newly hired engineers who have little or no background in radiation protection.
Expansion of NGET to a more comprehensive introductory training preceding or combined with OJT assignments should be considered.
3.7 Training-Summary a
Based on the appraisal findings, the following areas of training should be improved to achieve a fully acceptable program:
1.
Discussion in NGET, RCT, stationman, and maintenance training programs of low-level exposure effects and their relationship to health physics controls (access, contamination, respiratory protection, surveillance) employed at the station.
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Priority of RCT retraining.
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Emphasis on basic health physics concepts and skills in RCT retraining.
The appraisal team also recommends that consideration be given to expanding introductory training on radiation protection for newly hired personnel (operators, stationmen, maintenance, engineers) and to basic systems training for RCT's.
4.0 Exposure Control 4.1 General Review of the exposure control program at Quad-Cities, together with review of the corporate programs during the Zion appraisal, indicated that the basic resources are available for an excellent exposure control program. Program quality, however, is diminished by the absence of minimum performance criteria, absence of effective internal audits to ensure compliance with the criteria, and absence of strong guidance and support from the corporate office.
Station personnel are aware of the shortcomings and have managed to maintain a program of generally acceptable quality.
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4.2 External Exposure The external exposure control during routine operation utilizes a combination of "digidose" instruments, time keeping, self-reading pencil dosimeters (QCNPS employees or contractor personnel in controlled areas), paired non-self-reading pencils (non-QNPS employees) and film badges.
A TLD system was installed before the la=t outae,e for experimental purposes and to augment the dosim ;ry picgram during the outage. The results of the film badge readings are the primary source for personnel exposure data.
The information gathered from the other exposure measuring devic is used only when the film badge data are missing or known to be in error.
Pencil dosimeters are given a partial quality assurance test, initially and every six months.
The testing is comparable to that suggested in ANSI N13.5 " Performance Specification for Direct Reading and Indirect Reading Pocket Dosimeters for X and Gamma Radiation," except for drop testing. Addition of the drop testing procedure could eliminate some of the problems with totally dis-charged pencils or unbelievable results. The minometer used to read the indirect reading pocket dosimeters presently is not covered under any maintenance or quality assurance schedule.
Approximately 700 pocket dosimeters were purchased for use during the recent outage. Following the outage about 125 of the 700 new pocket dosimeters were located. This lach of control was seen in other areas of dosimeter issuance. During the past outage, several documented cases were recorded where dosimeters (film and TLL)
assigned to one individual were either inadvertently or deliberately worn by another worker. Neither training nor management directives clearly address the required proper handling of dosimeters or the
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importance of obtaining the best record possible for each worker.
Apparently no provisions exist for the dismissal of contractor personnel who deliberately tamper with or exchange dosimeters.
The establishment of a controlled dosimeter issuance (similar to the identification badge issuance) would eliminate many of the problems seen with contractor personnel (Section 5.2).
Before issuance, dosimeters are maintained in a well shielded location. Temperatures in the storage area and in the location where issued dosimeters are placed appears to present no problems.
Under the current Laundauer contract an insufficient number (3)
of control (background) dosimeters are supplied with each batch-of film dosimeters. However, the Rad Chem staff have used
unissued dosimeters as additional background controls thereby
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effectively making the number of controls edequate. The present film badge contract does not include a formal spike testing program. Over the past two years, the Rad Chem staff have been performing an unofficial blind testing program. The results suggest that a bias may exist with the exposures measured by the
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film dosimeters. However, the present calibration facility is
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inadequate for a proper blind testing program; thus, additional work is required.
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-An intercomparison study was performed between the TLD system and the film badges. The TLD dosimeters and the Landauer film dosimeters were exposed by an outside contractor and then sent
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to Quad-Cities for analysis. The study was used to equate the TLD results to the film badge results so that the TLD system could be used to supplement the exposure control pr* gram during the outage. The accuracy and the precision of both ne TLD and film system were determined. The accuracy of the T dosimeters appears to be better; however, the precision of the film was better. Although the TLD reader was carefully tested for perform-ance specifications, no quality testing was performed on the TLD dosimeters. Based upon the conclusions of the study, the TLD vJstem was employed to provide rapid updates of worker's exposure.
However, use of the system was impeded by lack of corporate support for interfacing the TLD reader output to the computer based exposure-update system. The TLD program has not been formally adopted for routine use by the station nor included in any formal procedure.
The licensee has detailed procedures for tracking personal exposures using computerized daily exposure updates based on information ob-tained from daily pocket dosimeter readings and film badges. The system makes use of " alert lists" and approval requirements to call attention to persons whose exposures reach predetermined levels.
The system works acceptably, although with a great deal of effort
by the health physics group, especially during outages when exposures
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tend to run higher than normal. Three instances occurred during the last outage where inadvertently or possibly deliberately one person
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wore the film badge assigned to another. These were satisfactorily
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resolved by the licensee in investigation.
The licensee's practices appear to make some distinction between
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permanent Edison employees and contractor employees, in that the
former cannot exceed 1250 mrem per quarter or 5000 mrem per
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year without approval of a superintendent and a bargaining unit
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representative. The condition is part of the " Radiation Control Standards" agreed upon by negotiation between the company and the union representing CECO employees.
By contrast, contractors can be taken above these levels with the approval of the R/C Supervisor or his alternate.
Based on the appraisal findings, this portion of the licensee's program is acceptable. However, several matters should be con-sidered for program improvement.
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1.
Contractor exposure approval procedures equivalent to those for CECO personnel; 2.
Improved corporate guidance and support related to the external dosimetry program; 3.
Improved quality assurance testing of personal dosimeters.
4.3 Internal Exposure Internal exposure measurements (whole body counting and urine analysis) are supplied under contract by Radiation Management Corporation (RMC). Operations of the whole body counter (WBC)
depends on an associated computer.
If it fails, there is no means to operate i-a manual mode and station staff have not been trained to at.alyze the data.
It would be desirable for the station to have the flexibility of operating in the manual mode until repair or replacemer.t of the affected unit.
If the WBC fails, a " spot" urine sample is collected as backup.
This is not really satisfactory because of general inadequacies of spot sampling, time lapse before results are known, and uncertainties of urine sample for inhaled insoluble nuclides.
Case-by-case review of work history is needed to determine if waiver of whole body counting is reasonable or if one should be made at a later time or et another facility.
During the most recent outage, adequate backup was provided by an additional WBC which was used to ensure timely counting of new hires and terminating personnel.
Background subtractions were questionable.
Background is measured with a long (three hour) count on backshift and the result is used over the next two shifts. However, the current WBC location is subject to fairly rapid and extensive background variations (Section 9.4) that can result in false positive or false negative results.
In addition, a licensee offsite audit of April 1980 noted that the background count and standard source measurements were often missed during the outage.
The vendor supplied standard source traceability to NBS was eight to ten years old. The sources were produced and calibrated in a flat configuration but are used rolled up to fit into the WBC phantom for checking calibration. No data were available to demonstrate source integrity in their present condition. The station does not maintain a set of reference standards for use as an internal audit. All QA is done by the vendor. Summaries of potassium-40 or of background measurements are not supplied to the station.
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Problems have variously been experienced with the new teletype
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unit, with bangup of the moving bed, and with L. s of data from the floppy disk.
Inadequate supply of vendor sy 'ied strip-chart paper for the background monitor has been a r ' 1 since early February.
Based on the appraisal findings, this portion of the licensee's program appears acceptable.
H, wever, program improvements, such as performance standards and guidance comparable to ANSI N343-1978,3j should be considered.
4.4 Respiratory Protection
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The licensee has implemented a respiratory protection program that includes procedures covering administrative and technical
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details required by 10 CFR 20.103 and Regulatory Guide 8.15.
Basic engineering controls in use include fumehoods in hot laboratories sampling areas, ventilation systems (Section 5.5)
and directed air flow.
Qualification of respirator wearers includes medical approvals, training, and fit testing. Appraisal team observations indi-cated that such matters as the use of engineering controls, the nature of possible hazards (particulates, vapors, oxygen defi-ciency etc.), the effectiveness of respirators available. and the control limits used should be more strongly stressed in training.
It was also noted that more strenuous and extended movements should be employed in mask fitting to ensure that a proper fit is achieved.
Qualified users are identified by an NGET card that indicates the category of masks tested.
Masks are cleaned, packaged, and issued by an RCT according to procedures.
The mask issuance area was crowded and floors were dirty. However, ficor and bench top smears by the appraisal team indicated no contamination problems. Masks available for issue are packaged in plastic after cleaning, inspection, and possibly minor repairs by the duty RCT. Several packages were opened and the masks inspected for flaws and tested for contamina-tion by the appraisal team. No problems were identified. Masks are smeared for contamination after use; a positive finding prompts a whole body count. This appears to be an adequate control techni-que in preference to routine nasal' smears, which usually are not effective for mouth breathers.
Mask issuance involves logging the user's name, work location, mask serial number, and issue time. The issue log also asks for the time returned and tha total time worn, but according to R/C personnel interviewed, these are often left blank because the masks frequently are not returned by users. The appraisal team observed unreturned masks during plant tours. The absence of 1/ ANSI N343-1978, "American National Standard for Internal Dosimetry for Mixed Fission and Activation Products."'
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duration of wear information would make it difficult to imple-ment a control program based on MPC-hours, as required by 10 CFR 20.103. R/C employees indicated that bringing this problem to the notice of station management in the past has brought only temporary improvement.
Control of mask issuance is also weak in that the mask issuance area is normally unlocked and unattended outside of day shift honrs (Section 5.5).
Self-service mask issue was observed several times by the appraisal team.
In one instance, a guard
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stationed next to the area explained (correctly) to an appraisal team member how to check out a mask.
Control of mask issuance was not one of the guard's assigned duties. Review of the issu-ance log indicated that information was being recorded in the same manner as during day shift. The extent of the users' know-ledge of airborne conditions in the area of use was not known, however.
The station's supply of respirators in the mask issuance room and in the storeroom appeared to be adequate for routine and emergency use.
Overview of the internal exposure program, including respiratory protection, was a collateral assignment of one of the professional HP's.
This individual, who has since left the company, appeared knowledgeable about the program and aware of the weaknesses.
He was observed to be actively involved and was available for con-sultation with RCT's on problems.
He stated that he was largely self-trained on the fit testing apparatus and that he, in turn, trained the RCT's.
Based on the appraisal findings, better control of mask issuance and return should be enforced in order to achieve a fully accept-able program.
4.5 Occupational Exposure Records The occu ational exposure records system involves the summation r
of data by a computer program operated by corporate and the accumulation of data on many different forms at the station.
The system exhibits a serious absence of quality necessary for accumulating and maintaining good legal records for the individual and the corporation as suggested in ANSI N13.6 " Practices for
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Occupational Records Exposure Limit System."
The occupational exposure records system suffers from the absence of formal criteria for the accumulating, recording, reviewing, documentating, and retaining occupational exposure data. A review of the lost dosimeter reports, microfiche official record, the " dud" lists (a computer generated list of umatched results),
and the Landauer reports revealed many inconsistencies. The following are examples of inconsistencies noted:
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(1) A dosimeter listed but no' exposure provided for the two week
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period.
(2) A dosimeter issued to worker A was worn by worker B.
The additional exposure ts determined by pencil readings was added to worker B's record, but no correction was made to worker A's record; This practice is deemed " conservative."
(3) No explanation of the dose assigned in lieu of a lost dosimeter.
In many instsuces, a number is written down with no reference to its sourse.
(4) Wrong dates or inconsistent dates between data sheets.
(5) Lost dosimeter reports not signed or dated by the person performing the work. Also, report not reviewed nor signed by lead health physicist or Rad Chem Supervisor, even though
space is provided on the form.
i (6) Discrepancies between the official record results of an in-
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dividual's exposure and the information provided on the investigation report.
Discrepancies were noted in the review of the occurrence reports.
Report 80-2 was not signed, reviewed, or approved. At least one report was several months overdue. Employee's names are included in the reports rather than being coded.
The computer program used to generate the " official record" has
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the capacity to provide a complete history of the dosimetry actions associated with an individual's record; however, the system currently is being used for a clerical function only.
Changes are made in the records without any provision for appropriate notes being entered as to why the changes were made.
.i The replaced results are' deleted from the computer program rather than being coded as'not appropriate and left on the record. This is contrary to accepted scientific and legal data collection practices.
I The various dosimetry records (film results, TLD results, time-keeping, etc.) for occupational workers are maintained inconsis-tently. Selected items are located in various files through the Rad Chem office. No formal criteria have been established for retention of the supporting dosimetry records necessary to recon-struct exposure scenarios. As noted previously, many reports are not dated, signed, or reviewed.
Some reports, such as the " dud lists" and Landauer film badge issuance sheets, are useful'in identifying and explaining discrepancies but these records are maintained for only one year, i
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A generic problem was identified in proper maintenance of occupa-tion records and exposure control.
In obtaining and providing data for transient workers, a problem sometimes arises due to the variation in the quarterly ending dates within the nuclear industry.
Be ad on the above findings, this portion of the licensee's c
predram appears to be acceptable, but the following matters should be considered for improvement of the program: better utilization of the computer system, formalized review of all records and reports, criteria for dosimetry supporting record storage, and better documentation on lost dosimeter evaluations.
4.6 Emergency Conditions
Adequate arrangement has-been made with Landauer to provide dosimetry services under emergency situations. The current contract provides for emergency processing within approximately eight hours of receipt at the contractors facility which is approximately three hours by automobile from the station. The station's in-house TLD system could be used for backup and to give a shorter turn around time provided that the processing equipment is located in an accessible area with reasonable background.
Additional facilities, including whole body counting, additional dosimeters, and additional respirators are available through sister stations.
Based on the above findings, this portion of the licensee's pro-gram appears acceptable.
5.
Access Controls 5.1 The restricted area for radiation protection purposes is essenti-ally the same as the protected area defined for security reasons.
It begins at the protected area fence which encloses the major buildings on site. Entry is through a guardhouse. A picture identification badge and two blind pocket dosimeters are required for unescorted entry beyond the guardhouse. The picture badge, which is color coded to indicate level of access allowed, permits identification of radiation protection training status.
Based on the appraisal findings, this portion of the licensee's program appears acceptable.
5.2 Controlled Areas Within the restricted area is the controlled area, which requires NGET training for unescorted access.
It begins at the entry
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from.the Service Building to the Unit 1 Turbine Building and in-cludes most of the posted (radiation, high radiation, radioactive materials, and airborne) areas at the plant. Entry past a security guard requiree the appropriate picture badge, film badge, and pocket dosimeters. The security guard is instructed to look for the proper personal dosimetry.
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Personal dosimetry required for controlled area entry is initially obtained at the Radiation / Chemistry (R/C) office (service building)
after completing the requisite forms (NRC-4 etc.).
Subsequently, badges are to be picked up from and returned to the gatehouse, where they are stored by number in badge racks.
The process is not controlled and there can be confusion as to which number applies to which badge rack slot. During the most recent outage, there were several instances of one worker wearing a badge assigned to another worker (Section 4.2).
Better control of dosimeter issuance is needed.
In addition, the possibility of integrating the security badge and personal dosimeter could be explored to ensure the wearing of appropriate dosimetry.
Individual entries are not recorded and personnel accountability would be a difficult matter, particularly when large numbers of nonstation personnel are present as occurs during an outage.
Accountability will depend on a compcrison of gatehouse and
assembly area muster records.
Precise accounting for persons
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who may have entered the Reactor Building would be of particular concern under accident conditions; currently, these entries are not logged.
The station is converting to a coded magnetic card system that will permit or deny access to vital areas, based upon computer entered authorization status, and will record entries and exits wherever the magnetic card is used.
It could simplify accounting for personnel entries, particularly if card readers are installed at emergency assembly areas.
It could also b; _xtended to better
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contro' entries to specific high radiation areas.
Based on the appraisal findings, this portion of the licensee's program appsars acceptable. However, improved control of dosimeter issuance should be conridered.
5.3 Radiation Areas
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The controlled area is defined and posted as a radiation area, although the dose rates in much of the area would not require it.
Hot spot stickers are used to call attention to areas where localized higher radiation levels exist.
Based on the appraisal findings, this portion of the licensee's-program appears acceptable.
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High radiation area (HRA) access is normally controlled by barricading, locking, and posting such areas.
For entry, a key must be obtained from the control room, where the date, tire, destination, and name of individual are logged.
Sixteen keys were available for checkout in the control room. The control room is supposed to be notified at the time of actual entry to and exit from the HRA. Revies of the key logs in the control room indicated that the latter notifications are either not being made or are not being logged faithfully by control room personnel.
The significance of this observation is that there is no continu-ing awareness of HRA entries and that an overdue exit likely would not be identified and investigated.
This is of particular concern for an operator who enters a nu2ber of HRA's during ex-tended inspection rounds without a survey instrument. Appraisal team members who accompanied an operator on rounds noted that radiation levels in most of the HPA's entered were less than 300 mR/hr. Exceptions were the south condensate demineralizer room, the MSIV room, and the LP heater bay, where readings of 500 to 1000 mR/hr were found.
Control weaknesses were also noted with respect to contractors working in the torus basement (554' level) of the Unit 1 Reactor Building. Control was exercised by an RCT-timekeeper on the ground floor near the access Ir.dder being used. Work area radiation levels were moderate (20-50 mR/hr).
However, the entire basement is posted as an HRA because of the high radia-tion levels that can exist in such areas as the Reactor Building Equipment Drain Tank (RBEDT) and RHR rooms that are accessible from the general torus area.
The entrances to these areas were not locked and there were no local signs to call attention to these high radiation areas. The RCT keeping track of sorker exposure by reading their self-reading dosimeters appeared to spend little time in the work area (Section 6.2).
The appraisal team believes that additional controls are needed tc guard against inadvertent exposure to workers who may wander unkncwingly into high radiation areas.
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Noncompliance with 10 CFR 20.203(c)(2) for failure to adequately control HRA access was identified on two occasions during the appraisal.
1.
An unposted and unbarricaded HRA existed near the sample hood on Unit 2 Reactor Building 647' level for several days in the period May 5-14, 1980. The apparent cause was acti-vity trapped in the drain line from the dryer separator pit.
Its existence was identified on R/C Department surveys and was known to the Operations Department, which was working
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to clear the lines. An appraisal team survey on May 10 identified the maximum radiation level as about 270 mR/hr at approximately 75 inches above the floor just outside the HRA fence surrounding the sample hood.
The source was a pipe that read 2 R/hr on contact.
Other readings outside the fence ranged from 15 to 100 mR/hr.
The area outside the fence was not posted or otherwise identified as an HRA.
2.
On May 5, 1980, at about 1600, the appraisal team observed a ladder temporarily lashed in place that gave unobstructed access to the posted high radiation area over the Unit 2 CRD accumulators. A permanent ladder normally used had been disabled by a locked lucite cover over its rungs. The temporary ladder was removed later the same evening.
Based on the appraisal findings, improvements are needed to ensure positive control of high radiation area entries.
5.5 Airborne Radioactivity Area Airborne radioactivity areas are clearly designated by appropriate warning signs. The airborne designation is based on actual air sample results or on work situations that carry the potential of airborne radioactivity.
The most frequently used criterion for establishingairbcrneareasisthepresenceoffloorcontamina3 ion exceeding 5000 counts per minutes per square foot (5000 cpm /ft )
over a significant floor area. This is a conservative limit based on possible resuspension and is imposed by the " Radiation Protection Standards" which have company wide applicability.
For special woek such as grinding and sandbie; ting of contaminated equipment, coctrols such as plastic tents and possibly temporary ventilation systems are used to confine generated aerosols and to limit spread.
Respirator requirements for specific areas are kept in the foreman's air sample log, which is updated daily. Respirators are obtained from the mask issuance room where cleaned and available respirators are stored sealed in plastic bags. Each respirator is identified by a number that is entered in the user log when a respirator is signed out.
Positive control over issuance is not maintained during offshift hours when the mask room is unlocked and unmanned (Section 4.4).
Based on the appraisal findings, this portion of the licensee's program appears acceptable. However, as indicated in Section 4.4, better control of mask issuance is needed for improvement of the program.
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5.6 Contamination
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Barricades, signs, and step-off pads (S0P's) are used to define contaminated areas and identify the need for protective clothing.
Clothing requirements for specific areas are stipulated on applic-able work permits by the R/C Department, based on the most recent survey data.
Information on specific areas is kept by the R/C foreman in a log that is updated as new surveys are completed.
The appraisal team noted that in at least one area, solid radwaste bandling, the smears were generally confined to high traffic areas and were not neces.;arily descriptive of the portions of a room or building less fregtently traveled.
The appraisal team observed that the controls were generally effective.
However, throughout the controlled area there was an acundance of contaminated tools and equipment, bagged or wrapped in plastic, awaiting decontamination, and contaminated trash awaiting dispcsal. Particularly messy conditions were noted around the Unit 2 drywell entrance (595' level) and in the Unit 2 trackway, where perhaps a few hundred bags filled and overflowed the compactor cubicle. This trash was awaiting compaction in drums and disposal as dry active waste. Radiation levels approached 100 mR/hr at isolated spots on the periphery of the stack. All of these were described as the legacy of the recently completed outage, when day-to-day trash handling was said to follow far behind owing to the shortage of stationmen who normally do t',is work. Slow response to requests for area decontamination during
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the outage was ascribed to the same cause.
Licensr_e employees
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also stated that problems with maintenance and contractors cleaning up after themselves were worse than usual during this outage. A related problem mentioned was the lack of well defined, convenient locations for contractors to decontaminate their tools.
This increased the post-outage workload and, in some cases, led to the setting up.of temporary decontamination sites (Section 9.7).
Iicensee personnel also stated that many of the outage contractors were not familiar with step-off pad procedures, with the proper method of wearing and removing protective clothing, and with required training by RCT's at the job site. This matter should be stressed more in contractor NGET training (Section 3.2),
although performance should continue to be observed at the job site by RCT's or some other experienced person.
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The appraisal team observed the practice of bringing tools and
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other items from the controlled area to the maintenance shop entrance for survey. The items are laid on plastic, usually
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unmarked, but by commen understanding are recognized as potentially_
contaminated, requiring a survey for clearance or other disposition.
The location is in a clean area of the service building, which
is generally not a controlled area.
It is also adjacent to the current whole body counter facility, thus potentially affecting background conditions there (Section 9.4).
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Slightly contaminated equipment is routinely brought for repair to the maintenance shop. Maintenance personnel rope off the tool or bench areas where work is done.
Licensee per:onnel stated that maintenance foremen usually notify the R/C Department, but not always. The appraisal team made direct and smear surveys of machine tools, floors, and horizontal surfaces in the shop, including a bench top area segregated for work on an axial vane fan. Direct readings on a thin window counter (Eberline HP210)
ranged frgm 100 to 500 cpm.
Smear su.veys showed up to 650 dpm/100cm beta-gamma in the roped off area and generally less than 100 cpm (direct) elsewhere, indicating reasonable controls at the time.
Licensee personnel stated that conditions deteriorate during a busy outage and that thorough surveys of the shop area were less frequent owing to other pressures. Review of survey records appeared to confirm these (Section 6.2) statements.
It is the opinio.' of the appraisal team that surveys of this area should, if any.hing, be more frequent at peak times, particularly in view of the fact that some maintenance shop personnel eat their lunch at a table in the corner of the shop.
Questionable controls were observed in the radwaste area, where operators and RCT's were observed wearing only shoe covers, gloves, ar'. street clothes in preparing drums for shipment.
(Section S.4).
This practice, together with perfunctory use of fri;kers, ray re-present overconfidence, considering the contamination potential.
The possibility of transfer of low level contamination from the area was underscored by the finding of measurable contamination on the clothing (worn in radwaste) of an appraisal team member when he was checked out by the whole body counter the following day.
The appraisal team observed work at the Control Rod Drive (CRD)
cleanup shop on the 647' level of the Unit 1 Reactor Building.
The shop is a controlled work area with specially adapted facilities (work bench, hood, shielded storage and dedicated tools) for use by maintenance repai rman. Full protective clothing and respirators were worn and exposure conditions were monitored by the RCT in attendance. Exposure rates at about three feet from the shaft end were about ten mR/hr at the beginning of the job and increased to about 250 mR/hr as disassembley progressed.
Assigned crews routinely expect exposures of about 65 mR.
Work proceeded routinely, except at one point where 20 to 40 grams of rust and particulate steel from corroded threeds spilled to the floor. A maintenance helper reacted immediately and vigorously mopped up the material wittmut first attempting to collect the bulk of the material.
This event suggested a lack of appreciation on the part of maintenance for the pctential spread of contamination.
Based on the appraisal findings, contamination control should be improved to achieve a fully acceptable program.
Among the measures that should be considered are:
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Better day-to-day decontamination and trash handling during outages.
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2.
Better training for contractors on protective clothing usage.
3.
More stringent protective clothing requirements in radwaste.
4.
More emphasis on contamination control techniques in training.
5.
Better tool clearance surveillance practices.
6.
Improved maintenance shop contamination surveillance during outages.
6.
Su rveillance 6.1 Area Surveys Area by area surveillance is assigned to available day shift RCT's at weekly or monthly intervals, as indicated by work in progress and the expectation of possible radiation hazards.
Survey findings are documented on prepared 8 " x 11" area maps.
Followin; a survey, the map and data are returned to the foreman's desk. At a later date reports are filed in the RCT control office.
Throughout the appraisal, situations arose where foremen were called upon to issue controlled work permits based upon their knowledge of condition in the reactor buildings. The foremen made good use of the records file and appeared to be well informed of the status of the primary hazard areas in the reactor buildings.
However, service building survey records were much less satisfactory.
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It is noted that laundry, maintenance shop, storage areas, and special support facilities had been omitted over a period of months during the outage. Floor plans for some areas were incomplete or out of date.
In one case, a master copy and copies were entirely missing.
A sampling of survey records going back six months was examined.
In many cases, records appeared to provide minimum survey data.
A large area or area subject to radiation oi contamination from many possible sources would be documented to show about half as many data points as would be necessary to demonstrate that all possible canditions in the area had been chcroughly and knowledge-
-ably moni ; red. Supporting statements, such as identification of the instrument used and conditions prevailing at the time of measurement, are generally absent from the record. Survey records are overly influenced by the daily familiarity of the RCT's end foremen and maybe insufficient to prevent misinterpretatica of current risk at a much later time by parties without the same continuum of information.
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During a routine survey of the Unit One Torus basement, the RCT
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explained that his routine procedure provided exposure information for the Reactor Operator on shift instrument status checks and crdinarily was not modified to benefit contract welders also working in the area. On this eceasion, however, the RCT made additional measurements in and around eight welders working on the hangar installation job. This action immediately pre.ipi-tated questions and discussion with the welders. This reaction suggested the need for better information for contractors con-cerning conditions at the work site.
During the past year, an Eberline floor monitor (24" G-M tube an rolling carriage) generally has been accepted for service builiing floor surveys. This specially adapted instrument permits rapid and comprehensive coverage of floor areas where limited spot by spot coverage previously had been routine.
An opportunity to compare quality of surveillance arose during the past year when the maintenance shop experienced widespread contamination by ruthenium-106. The floor monitor was deemed far more satisfactory
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and has been routinely used for service building floor surveys ever since.
However, it was observed that RCT's per.~orming these floor surveys were not documenting the results. Very few recent survey -records existed for the service building; these were con-fined to occasional wipe samples. This was at least partly an effect of the outage when certain surveys are dropped in favor of outage related work. Workload was apparently still heavier than normal as it was sometimes difficult to find an RCT available to conduct surveys of interest to the appraisal team.
From a review of RCT of surveillance and subsequent discussiou with MOT's and foremen, the Appraisal Team concluded that program quality could be improved if the foremen were to provide more supervision throughout the plant. The need for accessibility related to work assignments and issuance of controlled work permits tends to immobilize the foremen.
Such demands conflict with the equally important function of in plant observation and assessment of radiation protection work.
Based on the appraisal findings in this section and those in Section 5.6 and 9.8, it appears that improved contamination surveillance of the laundry and of the maintenance shop during outages is needed to achieve a fully acceptable program.
In addition, the following matters should be strongly considered for program improvement:
1.
Better meintenance of survey records to provide adequate information for long term usage.
2.
More in plant time by foremen observing and interacting with RCT's at the job site.
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More attention to keeping contractors informed of radiation conditions at the worksite.
6.2 Air Sampling Responsibility for air sample collection, counting, and recording is established as a separate assignment from area surveys even though the same locations and work sites are involved. The air sample assignment is rotated among all RCT personnel.
Six to
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ten air samples are routine with some areas monitored daily or several times a week.
Both low volume 4 4 high volume air sampling techniques are used.
Air sample data maintained in the foremen's air sample log were complete and timely, contrasting with the frequently sketchy area survey records.
Area coverage, sample frequency, and counting procedures followed acceptable standards of good practice, except that all sampling eff-st appears to be directed at certain high traffic areas.
Variations of air contamination level within extensively controlled worn areas, such as the torus basement or radwaste area, are apt to reflect high contamination on either side of the main traffic route and in remote work and storage rooms, and may not be appropriate 1y' monitored by measurements at a single location.
In addition to portable air sampling, building ventilation is continuously monitored by in-line air monitors.
Surface contamination exceeding 5000 cpm /ft requires respiratory protection, but verifying air samples are also taken.
This procedure appears ~to result in a conservative control program.
Based en the appraisal findings this portion of the licensee's program appears acceptable.
7.0 Instrumentation 7.1 General Health physics instrumentation capabilities (portable, fixed, process and control) associated with the radiation protection program vere reviewed, including instrument interpretation, calibrativn techniques, and maintenance.
Basic resources are available to provide the necessary high quality measurement and control program for the station. However, problems discussed in the following sections indicate that improvements are needed to introduce additional quality into the program. The program generally suffers from an absence of basic performance criteria and technical appraisal.
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7.2 Portable Instrtaents
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It woulo.ypear that the 50 dose rate instruments and approximately 80 other portable instruments should be adequate for routine use.
However, the number actually available was significantly less.
Because of out of service, past due calibration, and invento y problems, approxinately 21 dose rate instruments (CP type) appeared to be available for use during the appraisal. However, only a few (four to sixi were generally available at the RCT office; the rest were either in service somewhere in the plant or locked in an RCI's personal locker (Section 9.6).
A similar situation existed for other portable instruments.
In most instances, less than half of the total inventory was readily available for us,.
Instrument records indicated that approximately ten of the dose rate instruments were out of calibration, including instruments in emergency kits (Section 7.3).
However, calibration fre-quencies of the RCT-assigned instruments generally were within the quarterly requirements.
In some io" ances, the RCT-assigned instrument was calibrated more frequently than procedures required.
Calibrated instruments are stored in the RCT office, along with instrements that may be out of calibration.
Since no control of the office is maintained, instruments can be removed without the knowledge of the Rad Chem group. Therefore, problems were incurred in determining the actual instrument inventory and availability from the instrument maintenance and calibration records. Since an instrument accountability system did not exist, it was difficult to cross check instrument calibration records with the calibration stickers on the instruments. However, variances were seen between dates on instrument calibration records, the RCT's calibration work logs, and the instrument's calibration stickers. The variances appeared to result from clerical errors in transcribing information onto the records.
A portable instrument maintenance program adequate to maintain quality instruments exists at the station. Additionally, a contract exists between the station and the Eberline Repair Shop to handle significant repair of Eberline instruments. However, due to inventory and control problems, as noted above, an inadequate supply of portable instruments may exist for emergency use.
Check sources are not supplied with each of the portable instru-ments as suggested in ANSI N323, " Radiation Protection Instrumenta-tion Test and Calibration." However, adequate fan sources are
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available throughout the plant to permit periodic checking of the dose rate instruments. The portable GM instruments do not have a source of adequate strength to permit.hecking over all the ranges.
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Generally, the calibration-capabilities (including sources and
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instrumentation for maintaining traceability to the NBS) and the calibration facilities are adequate. However, there is no capability to calibrate neutron instruments at the plant.
Neutron calibration currently is performed at the Zion plant, but the Zion facility for neutron instrument calibration was identified as being inadequate during the appraisal of the Zion health physics program.
Calibration practices and procedures are well stated and followed by the RCT's.
Recently the cesium source calibration was recon-firmed by an outside consultant from the University of Michigan.
Based on a calibrated instrument provided by the appraisal team, the calibration curve for the source generally appears adequate.
However, the calibration appears to be in error for the low range (0 to 10 mR/hr), where a special shield is used to reduce the exposure rate. This error, which may be due to a change in the energy of the photons as a result of the addition of the shield,-may be as great as 50% in the conservative direction.
Problems were noted in the calibration of digital doserate meters (Xetex) and teletectors, due primarily to the absence of a calibra-tion jig to hold these instrumcats in place. Thus these instruments cannot be calibrated in reproducible source-detector geometry.
GM survey instruments are calibrated both with a source generator and a beta source. However, the CM tubes are not provided with a quality assurance test to ensure similar window thickness and response characteristics.
Based on the above findings, this portion of the licensee's program is acceptable, but improved control and accountability of portable instruments should be considered for improvement of the program.
7.3 Emergency Instruments The two Station Emergency Boxes are located in the east end of the storeroom building. Each box contains one medium range ionization chamber (Cutie Pie) and two Eberline PRM-4's with one HP-210, one HP-177, and one AC-3 probe. Each box also contains a high volume air sampler and other emergency equipment, such as respirators, anti-C clothing, ropes, signs, and sampling and decontamination equipment. Contents of the emergency kits were as listed in Procedure QEP 500-T2.
Instruments PRM-4 (S/N 2216)
and Victoreen CP (S/N 109) in the emergency boxes were last checked for calibration on October 11,'1979. Health Physics Procedure QRS 700-03 requires instruments to be calibrated quarterly; this, therefore, constitutes noncompliance with Technical Specification 6.2.B, which requires compliance with radiation control procedures.
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Additional instrumentation for onsite or offsite surveys during
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emergencies would be supplied from the Radiation Protection Office.
'The number and type of instruments immediately available.in the
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office were limited (See Section 7.2).
Except for the three Xetex,
which were 'out of calibration during the appraisal, and' the two teletectors, instrument ranges are limited to 100 R/hr. This would be~ inadequate based on experience from TM1, the performance criteria stated in ANSI' 320, " Performance Specifications for Reactor Emergency Radiological Monitoring Instrumentations," and the saturation problems sometimes observed with these instruments in high radiation fields.
Experience from TMI and the ANSI standarJ performance crigeria suggests that an instrument should exist for measurements up-to 10 R/hr.
The radiation background in the analytical laboratory and in the counting room after'a postulated accident have been calculated i
in a. report entitled " Post Accident Radiation Levels" by Sargent and Lundy, dated December 31, 1979. Both rooms, calculated to be in the shadow of the shielding provided by the control room,
would have radiation levels of approximately 2 mrad /hr.
These
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levels would probably make the analytical laboratory usable.
With some additional shielding around the detectors, the counting i
room also could be used after the postulated accident. The licensee currently has no alternate laboratory or counting facili-ties in place, but plans are being made and equipment ordered to provide on or near site alternate laboratory facilities.
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Based on the appraisal findings, additional high range (1000 R/hr or greater) portable instruments for emergency use are needed in order to achieve a fully acceptable program.
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7.4 Air Monitors Generally, air monitoring at the station is limited to potential r
release points.
Knowledge of contamination levels in work areas l
or areas that might be entered, such as the Torus area, are
normally obtained by collecting samples. The portable air monitors are several years old. These monitors have not been performance
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tested. Experience throughout the industry would suggest that leakage.can occur in the sample train, resulting in dilution of the
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sample. When air monitors are used as part of an effluent monitoring
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system,. leakage becomes a very important consideration in the quality of the sample.
The station recently received several new PING air monitors to be used within the plant. These are intended to be used as constant air monitors when calibrated.
Currently, problems in connection with the background subtraction portion of the system prevents adequate calibration. Performance tests have not been performed on these monitors. Attention should be given to the adequacy of the sample train, along with the response characteristics of the electronics
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Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the new constant air monitors should be calibrated and placed into service promptly.
7.5 Contamination Control Monitors An adequate supply of contamination control monitors, i.cluding friskers and portal monitors, was available. These instruments are checked periodically with a source; however, problems exist in the calibration techniques in areas with fluctuating background.
The monitors are electronically calibrated quarterly. The alarm tri? point is set in relationship to the ambient radiation levels mea sured at the time of calibration.
In areas where background radiation levels may vary, depending upon the work activity, the ability of the monitor to detect contamination may be impaired.
One example of such a problem exists in the hot laboratory, where the monitor was calibrated in a low background.
When hot samples are being analyzed, the monitor alarms, due to the high radiation backgrounds.
Several detectors were tested by the appraisal team using an uncalibrated source.
Sensitivity varied among the portal monitors.
The least sensitive portal monitors were found in the guardhouse.
Also, the logic circuitry of the guardhouse portal monitors may result in the release of contaminated personnel, especially
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during rush' hours. The same alarm is utilized to indicate either leaving the monitor too soon or contamination.
If the person leaves the monitor before sufficient countina time has elapsed, the alarm will sound, the red signal will light, and both will remain activated until the person reenters the monitor.
However, when the alarm and signal activate due to contamination, the contaminated person can step of f the monitor and the alarm and signal will automatically reset if the person was in the monitor for the necessary counting time. Thus, a contaminated person is left on his honor to report that he may be contaminated.
As noted in portable GM instruments, no quality assurance program
currently exists to test the sensitivity, wall thickness, and other operating characteristics of GM tubes used in the friskers or portal-monitors.
Based on the above findings, this portion of the licensee's program appears acceptable.
But to improve the program the licensee should reevaluate the calibration techniques used in fluctuating background areas and change the logic associated with the guardhouse portal monitors.
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7.6 Fixed Area Monitors An adequate supply of fixed area monitors is available at the station.
Good maintenance and calibration programs exist. The GE monitors are calibrated by use of the GE calibration source.
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The range of the area monitors does not meet the guidance of
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ANSI 320.
In most cases these instruments would be off-scale as a result of a serious accident.
A general problem identified in previous inspections still exists.
i More than 30 points are printed on the chart, making it virtually impossible to pick out individual monitors or to determine trends.
With the meter readouts this appears to be no problem, if the data are current, but reviewing charts at a later time would be virtually impossible.
It was noted in connection with the area monitors, as well-as process and effluent monitor readouts, that the annotation on the charts is not always sufficient to determine the author, date, and time of the notations.
Based on the appraisal findings, monitor recordings and date/ time annotations of charts should be improved to achieve a fully acceptable program.
7.7 Process and Effluent Monitors The number and location of effluent and process monitors appeared generally acceptable.
An exception was the radwaste discharge monitor, which shows an elevated background (approximately 3000 cps) owing to its location in the radwaste area. Background at the monitor varied by about ten percent, which is nearly the count rate change (approximately 500 cps) calculated to indicate release at the gross activity limit (10 ' uCi/ml).
Licensee representatives stated that a request for a new monitor in a low background location was made to the corporate Station Nuclear Engineering Department in 1979. Response was said to have been delayed first for a pending monitor study and later for TM1 related work.
Monitor maintenance by the Instrument Maintenance (IM) group appears adequate. Calibration is a joint responsibility of the IM group and
.the R/C Department. The former perform electronic calibrations and functional tests. R/C personnel assist in field calibrations using sources and are responsible for determining the relationship between monitor readings and fluid radioactivity concentration. For the main chimney and the Reactor Building vent noble gas monitors, monitor readings are correlated with activity concentration circulating in a closed loop containing the mon cor. The radwaste discharge monitor is calibrated with the detector placed in a spool piece containing a known concentration of cesium-137.
The quality of particulate and iodine samples is affected by sample line length and the amber of bends and connections ahead of the collection medium.
Le main chimney sample at the station has about 14 fittings ahead of the filter. This appears to be an example of field run piping without adequate review. The effect of this arrange-ment on representative sampling should be evaluated and measures should be taken to ensure that all such installations receive knowledgeable review.
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The range of the airborne release monitors will not meet the
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performance criteria of ANSI 320 or of 7JREG 0578. New sampling facilities proposed to meet these requi % ents are under con-struction (Section 11.2).
Based on the appraisal findings, the capability of drawing representative iodine and particulate samples from the chimney should be evaluated in order to have an acceptable program.
In addition measures should be taken to ensure adequate review of all sampling system installations and/or modifications.
7.8 Analytical Instruments The licensee has three pulse height analyzers for use in Gamma Spectrometry. The analyzers are calibrated using Amersham's mixed fission source annually.
Records of the annual calibra-l tions for 1979 were reviewed; no problem areas were noted.
Daily checks of instrument gain and zero offset are made by the
plant chemists; if needed, adjustments are made.
Health Physics Procedures governing the calibration and use of the Gamma Spectrometers are written and in effect. A chemist reviews the data sheets for trends and anomalies.
Since 1974, the licensee has achieved 89% accuracy on sample splits analyzed and compared with the hTC's-Reference Laboratory under the Confirmatory Measuremcats Program.
The licensee has two Wide-Beta automatic sample et,anters. The instruments are checked for efficiency daily using a cesium-137
standard. Backgrounds are also run daily. According to a licensee representative, a background exceeding 50 cpm requires decontamination of the equipment. Also, the efficiency check must fall within two sigma or the instrument is placed out of service and decontaminated. Recently one chemist has been put in charge of implementing a more effective quality assurance program for the Analytical Laboratory.
The licensee uses the same Wide-Beta instruments for counting
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analytical. samples. Alpha efficiencies are checked daily using a natural thorium standard. Alpha backgrounds are run daily.
Alpha contamination exceeding one epm requires decontamination of the unit. As with beta counters, if the efficiency check shows a difference greater than two sigma the counter is placed out of service and decontaminated.
Based on the appraisal findings, this portion of the licensee's program appears acceptable.
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8.
Radwaste Management 8.1 General Solid and liquid radwaste facilities are operated by a special unit reporting to the Assistant Superintendent for Operations.
-Five.radwaste foremen are necessary for continuous operation required to keep up with the inexorable generation of wastes.
There are no regularly assigned radwaste persor.nel below this
' foreman level.
Instead, each operator en shift spends one week out of five assigned tr radwaste.
In addition, an unassigned
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operator (roving extre) an each shift usually finds he spends all his-unassigned time assisting Rad Waste Operations.
The original GE radwaste process and storage system is.operat-ing, albeit modified and repaired many times.
In addition to keeping ahead of the waste load and maintaining equipment opera-tional, the radwaste foremen have successfully reduced liquid waste discharges. Allowing for tenfold variations during outages, liquid waste output has been reduced 60%.since 1976.
This trend is attributed to formal leak reduction measures, the adoption of
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dry cleaning machines in the laundry, and exhaustive attention to recycling of all reusable water.
In the winter of 1980, a 22-week outage preceded by three months during which commercial disposal sites were shut down left the station with a backlog of waste stored in drums. Thus, in addition to the regular basement radwaste storage facilities, caches of DAW drums were observed stacked in odd corners of every level of the reactor building.
This appearance of congestion and unplanned storage unavoidably creates the impression of bad housekeeping and faulty radwaste management. However, in the judgement of the Appraisal Team, no alternatives were evident at the time and under the circumstances.
To avoid possible repetition of this situation, a concrete storage building with 1800 drum capacity has been completed onsite. However, waste drum storage area in the Unit 2 trackway remains congested and exceeds routine standards of disorder.
8.2 Gaseous Radwaste heview of gaseous radwaste controls was limited mainly to examina-tion of'the monitoring systems, sampling, and counting procedures, release quantification practices, and monitor calibrations (Section 7.7).
Gaseous radioactive effluents are released via the joint Reactor Building Vent (RBV) and via the 300-foot chimney. Both discharges are continuously monitored for noble gas release and continuously sampled (analyzed daily) for iodines and gross particulates.
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Charcoal cartridges and particulate filters from each pathway are counted for iodine-131 and gross particulates daily; the filters are also composited and counted at the end of the month for particulates with half-lives greater than eight days.
Selected review of 1980 records ir.iicated noble gas releases at less than five percent of applicable limits and iodines and particulates at less than one percent. Through May 1980, iodine ano particulate limits were below the design objective.
In 1979, releases ranged from one to four times the design objective for particulates and iodines. Significantly greater attention to system maintenance and changing the basis for release quanti-fication from gross beta counting to isotopic analyses have combined to bring the releases within the design objective.
Based on the appraisal findings, this portion of the licensee's program is acceptable.
8.3 Liquid Radwaste Approximately 55,000 gallons of water are treated daily in radwaste. With suitable treatment most station water can be maintained at suitable quality levels and is therefore collected, treated, and reused. Water processing facilities includes a tank farm with 28 storage units of varying size located near the southwest corner of the Unit I reactor buildidg.
An analysis of tank size and use by radwaste foremen indicated emergency storage capacity sufficient for about eight days of routine operation.
Implementation of a formal leak detection program, adoption of dry cleaning for laundry, and increased success in reclaiming water for reuse has reduced discharges to about 3000 gallons per day during routine operation and to about 5000 gallons per day during an outage. This represents a 60 percent reduction over about four years.
Water that cannot be reused is ultimately routed to the 65,000 gallon River Discharge Tank (RDT), which is the only tank plumbed for discharge. The tank is isolated and the water is sampled and analyzed before release, which must be approved by the shift engineer. Since January 1980, release parameters have been based on GeLi isotopic analyses done before release. This method is considerably less restrictive and more accurate than the older method based on gross beta measurements.
Strontium-89, 90 anelysis is performed quarterly by a contractor on a proportional sample collected from tanks discharged. Alpha activity is calculated from the cobalt-60 to alpha ratio measured in the reactor coolant.
Because of fixed, low pumping rates (10 to 20 gpm), a discharge takes about two and'a half days. Discharges are made about every two weeks during normal operation and about twice as often during outages. Discharges are currently restricted to ten gpm, giving a minimum dilution factor of 2000.
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Water released is continuously monitored by the liquid waste
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discharge monitor (Section 7.7).
A composite sample collected from the discharge path to the river is analyzed on site and independently by a licensee contractor. A monthly proportional composite of all tanks discharged is collected and similarly analyzed.
Licensee records indicated that 1979 liquid releases ranged from 0.41% (second quarter) to 5.2% (fourth quarter) of the technical specification limits.
Based on the appraisal findings, this portion of the licensee's program appears acceptable.
8.4 Rad Waste - Solid Quad-Cities Station shipped 1132 cubic feet of solid waste in nine months of 1979 when commercial disposal sites were open.
When disposal sites reopened in late November, the station had radwaste drums and liners stored to capacity in the Radwaste Basement and had established a number of secondary depots through-out the building (over 500 drums). Despite accelerated shipments of 3149, 1919, 3954, and 2773 cubic feet in January through April, a backlog of stored drums was still highly visible throughout the plant.
In anticipation of future disposal service interruption a drum storage bunker was being completed.
Solid waste is shipped from the site in four basic packages. High concentration resins are shipped in Hittman Nuclear liners.
Low concentration resins are concreted and drummed in the Radwaste Department. Miscellaneous dry solids (DAW) are barreled at the work site then stored in the basement or other areas pending shipment.
Increasing use is made of a Munche.- Compactor system for dry solid waste. Compacted waste is shipped for disposal in 70 cubic foot steel bins efficiently and economically. Favorable reports of the Muncher process could not be verified by observation, because the compactor unit was buried in plastic bags in the aftermath of the outage (Section 5.6).
Ninety percent of Quad-Cities waste is routed to Barnwell, South Carolina, but token shipments are regularly forwarded to Hanford and Beatty to keep these avenues available should any form of rest.riction be imposed by Barnwell.
The Appraisal Team members accompanied an RCT on routine weekly survey rounds inside the solid waste facility. During the survey, two operators and a second RCT were taking barrels from storage, examining contents, sealir; he lids in place, and surveying the contents. A sampling of barrels serveyed measured 200 to 600 mR/hr at the surface.
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~Radwaste operators and RCT's work from a central control booth
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with shielded windows and walls but occasionally must leave the
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control booth to-attend to routine functions. As a result, direct exposure to the radwaste work crew is above the. station norm. RCT's i
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assigned to Radwaste for the day are presumed to have received the daily.100 arem exposure _ limit.
i The main working area of the Radwaste facility is subject to i
varying exposure-rates from drums in storage and drums being moved to the final preparation area. Despite the quantity of
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waste being handled, weekly contamination and air sampling do
not appear to indicate the necessity of full protective. clothing l
.for the radwaste work crew. Operators and RCTs engaged in preparing barrels for shipment wore only shoecovers and gloves with their street clothes.
The radwaste crew have recently conducted on-site pilot tests of
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Dow Urea Formalddiyde Casting resin for solidification and pack-
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i aging of spent Dow demineralizer resins.
It was reported that the system checked out and there was visible evidence of sectioned'
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liners opened to observe resia distribution and uniformity.
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i Approval of this system is pending.
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Based on the appraisal findings, this portion of the licensee's
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program appears acceptable.
9.
Facilities i
9.1 Radiation Chemistry
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The R/C office location is convenient for direct contact with
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management of the station and of other departments. The appraisal
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team observe d a high frequency of such interactions.
However, i
the space is badly overcrowded and not conducive to efficiency.
Station management has recognized this and has allocated space in a planned addition to.the service building, where offices for foremen, HP's,land RCT's, and a badge issuance are have been allocated. The area is scheduled for completion by the fall of 1981.
Although this move will provide relief, there is a risk that in physically separating the component' groups (chemistry-and health
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physics) of'the department intradepartmental communications will
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suffer. It also may separate the two RCT's normally on the backshifts and diminish the mutual support currently possible.
There is also the possibility that badge issuance in the_new location may.cause congestion in the service building entry corridor.
l Based on the appraisal findings, the' licensee's' plans for expanding R/C Department work space appear to be adequate. However,'considera-tio:.-should be given to minimizing the possible impacts discussed
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9.2 Analytical Laboratory
Analytical laboratory facilities appear adequate for routine operations. The hot laborstory, cold laboratory, and counting room are separate and appear to be of reasonable size. Counting room temperature and humidity control appeared to be adequate.
Iaboratories are equipped with fume hoods, sinks, and hood drains which go to retention tanks. Although the licensee has several lead caves in the hot laboratory for source and sample storage, shielding of the hoods and bench top areas appears limited and the licensee may have difficulty in handling high level radioactive material during en emergency. The Sargent and Lundy Shielding Study (December 1979) indicated possible laboratory area dose rates of two mR/hr at one hour af ter a serious accident.
If so, sensitive, unshielded counting equipment would have to be relocated or shielded.
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Backup laboratory and counting capabilities are adequate with complete facilities available at other licensee plants. Additional capability is available from the licensee's contractor, Radiation Management Corporation.
Based on the appraisal findings, high activity sample handling capability of the laboratory should be improved.
F 9.3 Personal Decentamination/ Medical Treatment Area The licensee has a small, poorly organized decontamination / medical area on the ground floor of the Service Building.
The area has a single, regular sized shower but lacks an examination table or other means of treating a person lying down. The space is too small for effective separation of competing activities (e.g.,
first aid treatment and decontamination). The space is also shared, inappropriately, with the whole body counter (Section 9.4).
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The licensee also has an offsite support hospital, which has an emergency room that can be set aside as a decontamination / medical treatment room. The hospital has been provided with decontamination supplies and equipment, and emergency room personnel have been trained in decontamination procedures by the licensee's contractor.
Based on the appraisal findings, the medical / decontamination facility should be improved to achieve a fully acceptable program.
9.4 Whole Body Counter Facility The wholebody counter facility is inadequate to provide the sensitivity and control necessary for a primary internal dosimetry measurement program. The whole body counter is located in the same room with the personal decontamination facility. This could lead to contamination of the whole body counter in the event of a severe personal contamination problem.
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l The whole body counter facility is subject to rapid changes in l
background, due to the movement and storage of contaminated equipment around the equipment decon facility and maintenance shop. As noted in Section 3.2 " Internal Dosimetry," changes in background have been erroneously evaluated as contamination.
Either the background will have to be stabilized or background l
counts will have to be taken simultaneously with whole bo(y counts.
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j Based on the above findings, improvements in this area are required j
to achieve an acceptable program.
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9.5 Calibration Facility The calibration facility is adequate for routine use, but would be unusable in the event of a serious accident resulting in high radiation levels. The facility is small, thus making it impossible to conduct all calibrations at that location.
Geiger-Mueller instruments are calibrated in the Rad Chem Laboratory. Background at the facility is subject to variation at times when activity changes in overhead pipes. This can affect quality control when spiking dosimeters at low exposure levels.
However, the licensee is well aware of the limitations of the facility. Moreover, the licensee has done a good job, with the aid of consultants in characterizing the exposure conditions within the facility.
Based on the above findings, this portion of the licensee's program is acceptable, since the licensee is aware of the limita-tions of the facility and utilizes contractor facilities.
9.6 Instrument Storage Facilities The instrument storage facilities, which consist of a series of shelves in the unlocked RCT office, do not provide adequate security for or control of the instruments. Adequate control is provided for the instruments in the emergency kits and for the instruments assigned to the RCT's. However, with many of the RCT assigned instruments locked in personal lockers, difficulty would be en-countered in attempting to obtain the instruments rapidly in the event of an emergency (Section 7.2).
Based on the appraisal findings, an improved storage facility and a means of ensuring ready availability of enough emergency instruments are needed to achieve a fully acceptable program.
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9.7 Equipment Decontamination The major equipment facility for the station is situated in the l
North Maintenance shop.
It is isolated from the shop and shielded
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to a limited extent by a concrete wall.
The facility is provided with a high volume exhaust hood over the work bench. Ultrasonic cleaner drain lines run to the waste collection tank. Maintenance
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men working there exercise routine contamination control procedures and are often supported by RCT's. Despite the absence of a roof over the facility, control of airborn contamination generated in the shop appears to be acceptable, judged from local monitoring and air sample records.
Items to be worked on are normally brought to.the shop from i
various locations in the plant. Often this has.been done without appropriate planning with or notice to the R/C Department.
Occasions of contamination spread to the service building and maintenance shop were mentioned by several persons interviewed.
The appraisal team suspects that this problem may result from improper understanding of contamination control procedures on i
the part of maintenance foremen, who sometimes arrange for the I
work without et.'sulting health physics or the RCT foremen. The i
RCT foremen somesimes do not know what work is in progress in the
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shop until it is too late to avoid trouble by proper preparation.
Contract maintenance requiring tool or equipment decontamination usually occurs at temporary controlled work sites in the reactor building. While appropriate crea restrictions and contamination I
controls are normally obtainable by means of plastic sheet and rope barricades, these temporary features tend to be compromised
by long use and abuse. Widespread deployment of temporary work
shops, as observed during the appraisal, requires extra surveillance j
and causes increased opportunity for the spread of contamination.
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In addition, when assigned work at the temporary location is complete, the area is not always promptly decontaminated and disassembled, thus prolonging congestion, and the potential for contamination spread, and possibly causing unnecessary exposure.
i Based on the appraisal findings, tool and equipment decontamination practices should be improved to achieve a fully acceptable program.
Among the matters that should be coasidered for improvement are better l
radioactive material movement procedures that emphasize the role of the R/C Department in such movements, more emphasis in training on contamination control procedures and their relation to possible health
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hazards, and better management definition and control of the establish-
ment and duration of temporary decontamination sites.
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9.8 Laund ry
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The station operates an in-house laundry for protective clothing, using two to three stationmen under the supervision of two foremen, who also have other'responsioilities.
Located at the principal access to the controlled area, it establishes a point of departure
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and return for operators, maintenance men, and RCI's proceeding to j
work assignments. The laundry provides a six-inch concrete shielded i
bin'for return of contaminated garments, a hooded table for emptying bags and sorting, two vat washers for rubber goods, two HEPA filtered driers, three dry cleaning machines for cotton goods, a monitoring bench (with 24" GM probe), and bins for laundered, reusable clothing.
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Stationren serve one-week assignments in the laundry as part of their initial plant familiarization. The assignment includes
going into the plant to retrieve protective clothing left at
step-off pads by work crews. The foremen apparently had no quality control procedures to confirm that garments offered for reissue were, in fact, suitable. The laundry work area (exclusive of the clothing reissue area) is controlled with step-off pads as a contaminated area.
On May 10 an appraisal team member independently surveyed the
laundry in order to judge its effectiveness. Radiation levels were about one mR/br, generally, increasing to about ten mR/hr near the washer and soiled clothing hampers. Licensee personnel indicated that a portion of the one mR/hr general background came from condensate storage tanks immediately west of the building.
R/C Department records indicated that a comprehensive laundry survey had not been done for three months.
This is too long, considering the role of the laundry in exposure control. Laundry surveillance is also somewhat questionable because of the general
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use of Eberline R0-3A ion chambers for surveys. The lowest
range for this instrument, zero to 100 mR/hr, will miss the nuances of radiation levels resulting from laundry contamina-tion. A more effective instrument would be a standard GM survey meter with conventional ranges up to 20 mR/hr.
Extensive smears were made of floor, bench tops, and equipment i
surfaces. With a GM thin window pancake detector, these smears read from 400 cpm (interior surface of dryer #1) to 22,000 cpm (floor in front of the washer). Dust from the air sampler motor on top of the washer read 1100 cpm. Surprisingly, the daily air samples indicated no resuspension of the surface contamination.
Even so, the stationman practice of wearing respirators while handling laundry is prudent.
A sampling of 21 gloves and 12 coveralls were monitored to check effectiveness of the laundry process and quality control. Careful use of the table-mounted 22-inch laundry monitor (ambient back-ground of 2300 cpm) indicated that about half of the garments exceeded the station laundry limits (3000 cpm) for reissued clothing given in QRP100-1, Section 26. Pancake detector readings of the same garments give direct readings up to 15,000 cpm. This condition constitutes noncompliance with Technical Specification 6.2.B, which requirea adherence to plant radiation control procedures.
Two days later, four "over level" garments were used to measure the significance of spot contamination by means of TLD's taped
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to the contamination. After 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the TLD's were removed j
l and processed. Exposure rates ranged from two to ten mR/hr as measured by this test.
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On Monday following the laundry survey, the inspector observed stationmen surveying coveralls at the n:onitor bench.
In haste to keep up with the morning workload, coveralls were passed over the GM rapidly (i.e., approximately three seconds per coverall)
and the upper part of the garment was drawn past the GM tube from 8 to 16 inches above the tube. Only the lower part of the garment waist and legs came close to the detector albeit too quickly for a 3000 cpm area to indicate.
The measurements conducted by the inspector also tend to question the 3000 cpm laundry acceptance limit.
Presumably this was intended to allow no more than 0.25 :aR/hr spots of residual contamination on clothes. Depending upon the gamma sensitivity of the monitor probe employed and the monitoring techniques in use, 3000 cpm may be too high for acceptable protection. The effect of background on the laundry monitor should also be evaluated.
Based on the above findings, attention to the following areas are necessary to achieve acceptable performance:
1.
Increased supervision and training for statiomen laundry operators.
2.
Thorough decontamination of the laundry facility 3.
Resumption of a formal survey program 4.
Institution of a laundry quality control program.
5.
Evaluation of laundry monitoring including the effect of background from the condensate storage tanks and other sources.
10.
ALARA No formalized ALARA program has been established at either the corporate or the station level. Man-rem goals are not established for the station, for individual departments, or for specific jobs. The station does participate in a radiation evaluation program (REP) established by the corporate office.
REP provides a record of exposure by work task and should be useful in identifying jobs where ALARA review would be bene-ficial. At present, however, this information is not used routinely in work planning by other departments.
Licensee corporate representatives have stated that a contractor would be retained to develop a formal ALARA program for all Ceco stations.
It is particularly needed at Quad-Cities, where by mid-May the 1980 dose was about 2400 man-rems. With continued routine operation, NRC mandated modifications, and a fall outage with sparger and core spray work, the total for 1980 could exceed 5000 man-rems.
Significant dose savings might be realized from an aggressive, stationwide ALARA program.
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Even without a formalized ALARA program, many ALARA applications have been implemented at the station over the years.
An ad hoc committee which assessed methods of decreasing radwaste area exposures is a good example. Significant exposure reductions resulted from shield-ing and better remote handling of radwaste drums.
Improvements are still needed to reduce exposures associated with such work as de-contamination wiping of drum external surfaces, solidified drum inspection for liquids, and cask loading. These are matters that could be pursued by a dedicated ALARA group.
Other areas of ALARA implementation include the use of water shields
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in the torus area, a new procedure for changing condensate demineralizer
elements, and modification and shielding of cleanup pumps. During the recent outage, closed circuit TV (CCTV) was used to maintain visual contact and aid timekeeping during sparger work in the dry well.
It not only reduced RCT exposure but was also used to inspect the work performed.
CCTV is also being used in the radwaste basement area to reduce operator entries and exposures.
A radwaste foreman called attention to a collection of radwaste tank farm photographs showing the location of valves and flowmeters and their relationship to demineralizer trains. The photo study originally was assembled to demonstrate the complexity of the tank farm to authorized visitors, while avoiding the necessity of actually entering the area.
More recently, the photographs had been used for instruction of operator
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trainees. The use of visual aids such as photographs and CCTV could
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probably be extended to many other areas.
Based on the appraisal findings, improvements are needed to achieve a fully acceptable ALARA program. Consideration should be given to incorporating the following as elements of the program:
1.
A dedicated ALARA group headed by a health physicist.
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2.
Involvement of all station personnel, including contractors, by establishing an ALARA committee, training, and other incentives in an effort to reduce station exposures.
3.
Full implementation of the REP program, including its use in ex-posure prediction.
4.
Formal review of station modifications and other work, based on man-rem expectations.
11. Accident / Reentry 11.1 In response te item 2.1.6.a of the TMI-2 Lessons Learned Task Force Report (NUREG-0578),thelicenseesubmittedforNRRreview?3f'8#8" for controlling leakage of systems outside of containment.2 -
2/ Itr. D. L. Peoples (Ceco) to H. R. Denton (NRR) dated 1/1/80.
3/ Ltr. D. Ziemann (NRR) to D. L. Peoples, (CECc) dated 3/5/80.
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The program involves daily recording of water inventory and
periodic quantitative and qualitative leak determinations on the
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following systems: high pressure coolant injection (HPCI),
reactor core isolation cooling (RCIC), residual heat removal system (RHR), reactor cleanup system, core spray, primary coolant sample system, main steam, and standby gas treatment system (SBGTS).
Baseline leakage measurements were made at the inauguration of the program. The appraisal team limited its review to confirmation that the station is implementing the program.
11.2 Post Accident Sampling The shielding study by a licensee contractor indicated that radiation levels in the reactor buildings under worst case acci-dent conditions would prevent access for reactor coolant and containment sampling. The licensee is in the process of construct-ing sampling facilities outside of the reactor building to permit sample collection under worst case conditions.
Completion is scheduled for January 1981.
An interim system to permit reactor coolant sampling under less than worst case conditions has been established.
It consists of a continuously flowing, closed loop from each sample hood extended to a location just outside the airlock at the entrance from the turbine building on the 647' level, where provision is made for taking a sample. A procedure, QCP 600-8, dated December 1979 had been written for taking and bandling this sample.
No special provisions had been made for containment (drywell)
sampling under less than worst case conditions.
Licensee repre-sentatives stated that under less than worst case conditions allowing reactor building entry, the normal sampling stations would be used.
The current systems for chimney and reactor vent monitoring do not meet the dynamic range recommended in KUREG-0578 item 2.1.8.b.
An interim procedure, QCP 600-10, dated December 1979, has been written for estimating chimney releases by direct measurement on a
the sample line with a portable survey meter. The graph relating meter reading (mR/hr) with release rate (curies per second)
indicates that the system is rather insensitive and may not be reliable under worst case dose rate conditions postulated by the shielding study.
Licensee representatives indicated they are prepared to take grab samples as an alternative.
According to licensee representatives, R/C management personnel would be responsible for performing these procedures and could be present on site within 40 minutes. RCT's had not been trained in these procedures but were expected to be trained during the 1980 annual retraining. The appraisal team believes all RCT's i
should also participate in a walk-through of these procedures.
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RCT's are always present onsite and there may be times (bad weather, communication snags, etc.) when R/C management will be unable to respond as planned.
Based on the appraisal findings, RCT training on interim emergency
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procedures is needed to achieve a fully acceptable program.
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12.
Exit Interview The results of the appraisal were discussed with representatives of corporate and station management (Section 13) at the conclusion of the appraisal on May 16, 1980. The findings were classified into three categories.
Significant appraisal findings are described in Appendix A to a.
the letter forwarding this report and are summarized at the conclusion of applicable sections of this report. Written
responses to these findings are required of the licensee and
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actions taken will be reviewed during subseouent inspections.
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b.
Findings of lesser significance, but which are considered important to a quality health physics program, are discussed in applicable sections of this report. No written response to these findings is required, but progress in these areas will be observed during
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subsequent inspections.
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Apparent noncompliance items identified during the appraisal are c.
specified in Appendix B to the letter forwarding to this report.
Response to these items is required and responses will be veri-fied during subsequent inspections.
13.
Persons Contacted Ceco Quad-Cities Station
- N. Kalivianakis, Station Superintendent
- K. Graesser, Assistant Superintendent, Administration and Support Services
- T. Tamlyn, Assistant Superintendent., Operating
- R. Bax, Assistant Superintendent, daintenance
- D. O'Connor, Personnel Director
- R. Flessner, R/C Supervisor
- L. Gerner, Technical Staff Supervisor F. Geiger, Training Supervisor
- T. Kovach, Lead Health Physicist-P. Shafer, Health Physicist W. Hunyon, Health Physicist G. Sikkema, Chemist
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T. Markwalter, Chemist V. Smith, Chemist J. Piercy, R/C Foreman
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O A. Schabilion, R/C Foreman M. Whi'emore, R/C Foreman J. Miller, Engineering Assistant, R/C R. Tank, Engineering Assistant R/R D. Skiersont, Engineering Assistant, R/C G. Conschack, Senior Operating Engineer R. Robey, Operating Engineer D. McCarthy, Shift Engineer R. Bohn, Shift Foreman s
D. Strang, Radwaste Foreman G. Klone, Radwaste Foreman J. Forrest, Staff Assistant, Operating 1. Frischhorn, Stationman Foreman G. Demos, Stationman Foreman R. Gamper1, QA Inspector
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J. Heilman, QA Engineer
- K. Hansing, QA Engineer D. Rajcevich, Master Instrument Mechanic S. Simpson, Storekeeper D. Jessen, Engineering Assistant, Technical Staff D. Clark, Mechanical and Electrical Group Leader, Technical Staff J. Eagle, Technical Staff Engineer J. Wunderlich, Enginet-ing Assistant, Technical Staff Ceco Offsite
- R. Pavlick, Health Physicist, Technical Services Nuclear i
Non CECO
- N. Chrissotimos, Senior Resident Inspector, USNRC
- S. DuPont, Resident Inspector, USNRC
- W. Fisher, Region III, USNRC
- Denotes those present at the exit interview of May 16, 1980.
The appraisal team also interviewed other licensee and contractor personnel during the appraisal.
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