IR 05000309/1993019

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Insp Rept 50-309/93-19 on 930809-13.No Violations Noted. Major Areas Inspected:Mgt Organization,Alara,Control of Radiological Work During Refueling Outage & QA & Training
ML20024H968
Person / Time
Site: Maine Yankee
Issue date: 08/17/1993
From: Joseph Furia, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20024H967 List:
References
50-309-93-19, NUDOCS 9308310045
Download: ML20024H968 (34)


Text

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P U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-309/93-19 Docket No.

50-309

License No.

DPR-36 Licensee:

Maine Yankee Atomic Power Company 83 Edison Drive

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Augusta. Maine 04336 L

Facility Name:

Maine Yankee Nuclear Generating Station Inspection At:

Wiscasset. Maine Inspection Conducted:

August 9-13. 1993 Inspector:

,,Nh EM I/kU J. Fhria, Senior Radiation Specialist, date Facilities Radiation Protection Section (FRPS),

Facilities Radiological Safety and Safeguards Branch (FRSSB), Division of Radiation Safety

and Safeguard

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Approved by:

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'W. Pasciak, Chief, FRPS, FRSsB, DRSS date

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Areas Inspected: Announced inspection of the radiation protection programs including:

l management organization, ALARA, control of radiological work during a refueling outage,

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Quality Assurance and training.

Results: Performance in maintaining occupational doses ALARA has been generally good early in the refueling outage. Control of radiological work by the radiation protection staff has also been notable. Weaknesses observed included radiological worker practices and in limiting the number of personnel entering the charging floor of the containment during various radiologically significant evolutions. No violations of regulatory requirements were identified.

9308310045 930818 PDR ADOCK 05000309-G PDR

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DETAILS 1.

Personnel Contacted 1.1 Licensee Personnel

  • R. Blackmore, Plant Manager
  • D. Caristo, Radiological Programs Section Head i
  • J. Frothingham, Quality Programs Manager
  • R. Hayward, Quality Assurance Supervisor
  • E. Heath, Radiological Controls Section Head
  • D. Hickey, Radiological Controls Supervisor
  • R. Jordan, Senior Licensing Engineer
  • S. Nichols, Technical Support Manager
  • G. Pillsbury, Radiation Protection Manager
  • M. Readinger, Radiological Controls Supervisor
  • A. Shean, Manager - Training T. Shippee, ALARA Coordinator
  • M. Swartz, Specialty Training Section Head 1.2 NRC Personnel
  • C. Battige, Reactor Engineer Intern C. Marschall, Senior Resident Inspector
  • W. Olsen, Resident Inspector 1.3 Other Personnel
  • P. Dostie, State of Maine Nuclear Safety Inspector
  • Denotes those present at the exit interview on August 13, 1993.

2.

Radiological Controls At the time of this inspection, the licensee was entering the second week of a refueling outage, scheduled for eight weeks in length. The licensee established various performance goals in the radiation protection area for the outage, including:

(1) an administrative limit for occupational dose to any one individual to less than one Rem for the year; (2) no unplanned exposures; (3) total station dose during the outage not to exceed 396 Person-Rem; (4) total contaminated floor space less than 5000 square feet at the conclusion of the outage; and (5) total radwaste generated less than 6500 cubic feet.

In support of the outage, the licensee had augmented its normal radiological controls staff with 105 contractors, including 96 health physics technicians (90 being qualified as senior technicians) and 8 health physics supervisors. Licensee personnel were J

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assigned as work group leaders within the plant, with the contractors forming the work group. Licensee radiation protection management and radiological technical j

specialists remained the same since the last inspection.

i 2.1 ALARA The licensee establishcd a total dose goal for the refueling outage at less than 396 Person-Rem. Through August 11, total outage doses were 67.062 Person-Rem, which was only 46% of the projected dose for that date in the outage.

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Some of the reduced dose could be traced to the licensee being somewhat

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behind in its outage schedule, however even factoring this in, outage doses

were approximately 40-45% less than projected.

Dose savings were reali7ed primarily through the planned placement of lead i

shielding in key areas prior to the start of work at the beginning of the outage.

i A window was created in the outage schedule at the start of the outage to allow for radiological control personnel to have sole access to the containment i

for the purposes of placing shielding, decontaminating areas and conducting surveys prior to maintenance and engineering work crews entering the i

containment. Extensive shielding was observed throughout the containment, especially in the loop areas.

Of concern during this inspection was the number of personnel observed in the containment, especially on the charging floor, during potentially significant radiological work evolutions. The inspector observed both the lifting of the reactor head and the removal of the upper guide structure during the course of this inspection. In the case of the reactor head lift, the head had to be removed from the refueling cavity and lowered down to its storage location on the -2' elevation of the containment. Radiation levels on the underside of the reactor head were approximately 6 rad per hour (R/hr), and 3 R/hr on the top

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surface of the head. Radiation levels of 100 millirad /hr (Mr/hr) were found at the railing on the charging floor overlooking the refueling cavity. During this evolution,13 radiation workers and six radiological control technicians were

on the charging floor. Some of the workers had clearly defined purposes on the floor at this time, such as crane operation, crane signalman, etc., however

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several workers spent most of their time sitting in a low dose waiting area on the charging floor. While it demonstrates good ALARA control to keep

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personnel in a low dose waiting area, better ALARA control would have been

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for these people not to be on the charging floor. Discussions with licensee

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management and radiological controls staff indicated that part of the problem observed stemmed from the pre-outage sizing of the work crew, and the

inclination to send the entire work crew into an area when only a part of the

crew had a clearly defined need to enter the area.

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Similar problems were noted during the removal of the upper guide structure, and later during the removal of in-core instrumentation tubing, although radiological conditions were less severe during these two evolutions. In the case of the upper guide structure movements, approximately 25 radiological workers and nine radiological control technicians were on the charging floor.

A number of them were immediately involved in performing work.

In spite of this weakness, generally good control of radiologically significant work was observed. The chief technician assigned to the charging floor during the three significant evolutions observec' demonstrated clear control over the radiological aspects of the work activity. Non-essential personnel were directed to stay in the low dose waiting area, and personnel approaching the refueling cavity, especially during and immediately after the reactor head lift were challenged as to their reason for needing to be in close proximity to the cavity. During the head lift, personnel not directly involved in the crane

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operations were directed to stand behind water shields that were located on the charging floor, to reduce occupational dose.

2.2 Work Observatinns and Contamination Control At the time of the start of this inspection, the licensee was entering day 10 of the refueling outage, and had already experienced approximately 100 personnel contaminations, as documented in the licensee's contamination occurrer e reports (CORs). In response to this, a contract quality assurance inspector was assigned to observe worker practices in the restricted area, additional emphasis was placed on supervisors to tour the restricted area on a daily basis and observe their workers' performance, and additional observations by radiological controls supervisors of radiological worker practices were instituted.

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All radiological workers, including contractors, had previously been given a course in advanced rad worker practices, presented by the licensee's Training Department in both a classroom setting, and in a mock-up of a portion of the restricted area. In spite of these program improvements since the last

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refueling outage, a number of poor radiological worker practices were observed during this inspection, which could lead to increased personnel

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contaminations. These included workers repeatedly observed touching their faces while wearing protective clothing, including gloves, while working in contaminated areas, crowded conditions at the containment access point and poor frisking practices when exiting the containment. Containment access crowding is exacerbated by the fact that a high radiation field is located directly across from the personnel hatch inside the containment. Although the licensee undertook to place significant amounts of lead shielding on this door leading to the pressurizer, dose rates were still ten times higher near this door

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than elsewhere in this part of the containment. As such, workers tended to back up into the small area outside the personnel hatch waiting to remove their I

protective clothing. Under these circumstances, workers were often seen bumping and crowding into one another, often with a worker who just

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removed his protective clothing (PCs) coming into contact with one still wearing his potentially contaminated Pcs. Frisking problems were especially evident at the containment personnel hatch, where workers were to remove their dosimetry as part of the PC removal process and place the dosimetry on a table located nearby. Once a worker finished removing his Pcs, he was to

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survey his dosimetry using an Eberline Model RM-14 with probe for this purpose. Approximately 75 workers were observed during this inspection exiting the containment, with one-third to one-half improperly frisking their dosimetry. Deficiencies observed included surveying only one side of the dosimeters, failing to survey their hands prior to picking up the frisker probe, frisking at a rate well in excess of the two inches per second taught during advanced rad worker training, holding the probe 4-6 inches away from the l

surface to be frisked (recommended distance by the licensee was 1/2 inch),

I and not frisking the dosimetry at all.

The high rate of personnel contaminations was indicative of continued problems with contractor radiation workers previously observed at Maine Yankee. Most of the contractors used during outages are unfamiliar with work in radiological areas, having previously worked at non-nuclear commercial shipyards and at lumber mills. As such, greater reliance on training and i

supervisory control by the license must be utilized with these persons.

Significant improvements in training were made since the last refueling outage.

Further training improvements, and greater control of workers while in the restricted area will be reviewed during a future inspection in this area.

l 3.

Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the I

conclusion of the inspection on August 13, 1993. The inspector summarized the purpose, scope and findings of the inspection. The licensee acknowledged the fmdings of the inspection.

4.

Radiation Protection Imorovement Procram On July 22,1993 licensee representatives made a final presentation on the Radiation Protection Improvement Program (RPIP) to NRC Region I management. The RPIP was started in late 1990 in response to a number oflong-standing NRC concerns with the radiation protection program at Maine Yankee. During the RPIP, essentially all

licensee procedures and programs within the Radiation Protection Department were l

reviewed and revised. The RPIP procedures review and upgrade was completed this l

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spring with the issuance of new procedures and program documents in support of the

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radiological instrumentation program. The licensee indicated at the meeting that

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quality assurance audits were being scheduled to review the success of the RPIP. The results of these audits will be reviewed during a future inspection.

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ENCLOSURE 2

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MEETING AGENDA i

MAINE YANKEE RADIATION PROTECTION PROGRAM-

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MANAGEMENT MEETING

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USNRC, REGION 1-l

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JULY 22,1993 l

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INTRODUCTION G. M. LEITCH l

l COMPLETION OF RP IMPROVEMENT PROGRAM -

G. D. PILLSBURY i

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PART 20 IMPLEMENTATION LESSONS LEARNED G. D. PILLSBURY

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i 1993 ALARA PERFORMANCE E.M. HEATH l

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l 1993 REFUELING PLANS S. E. NICHOLS i

i LOW LEVEL RAD WASTE UPDATE S. E. NICHOLS

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CLOSE R. W. BLACKMORE i

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RADIATION PROTECTION PROGRAM UPGRADE Scope

Began Fall of 1990

Finished May of 1993

RP Staff increased 50%

Program increased From 80 Procedures To

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150 Process included Review Of Inspections, Audits, in-House Data - 5 Yrs Data MORT Assessment

Programs / Procedures Created or Revised To Current Standards Using Experienced Contract Specialists Incorporated items From 1st Bullet Used Tech V&V and Multi-tier Management Review Prior To Approval

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RP Personnel and Company Training

QPD Checks Following Program implementation i

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Improvements Realized i

Reduced Station Exposure l

1989 3 Year Ave 501 Man-rem

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1992 3 Year Ave 414 Man-rem Projected 1993 3 Year Ave 329 Man-rem Reduced Personnel Contaminations 1990 552 1992 417 Current 1993

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Contaminated Floor Area r

1989 16000ft2 (17%)

1993 4500ft2 (04%)

Advanced Radworker Training Maine Yankee

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Contractors

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NRRPT Certified Technicians 13 Techs (65%)

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MORT ASSESSMENT POST OUTAGE BY QPD

RE-EVALUATE ALL PROGRAM AREAS

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GENERATE REPORT AND NEW MORT CHART

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COMPARE CURRENT STATUS TO ORIGINAL WESTINGHOUSE

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REPORT

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10 CFR 20 IMPLEMENTATION

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Process

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Used Same Process As RP Program Upgrade

Joined Region 1 RPM Group j

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Identified Non-procedure Changes Needed

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Assigned Responsibilities and Due Dates l

Tracked Progress Weekly Vs Schedule

Held Quarterly Status Meetings With Oversite

Committee

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Changes

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s Labor Cost < $200,000 (Not Counting MY Labor)

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Training Joint Effort with NETA on GET/GPK Revision Began Special RP Training in 1991

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Conducted Overview Meetings for All MY Departments

During 1992 Trained RP Personnel February 1993 Trained All Staff March 1993

Additional New Part 20 Training for Contractor RP

Techs Prior to '93 Refueling Special Training Sessions on Respiratory Protection

Policy F

Lessons Learned

Used in-House Personnel to Development Procedures which Enhanced their Knowledge of Part 20 Lessons Learned from RP Program Upgrade were Applicable to Part 20 Training Participation Early in Procedure Development Facilitated Lesson Plan Revisions

RP Supervisor / Specialist involvement In Training Sessions Provided Answers to Questions Incorporated Training Feedback Workshop Helped Us to Understand NRC's intent for New 10CFR20 Full Benefits of New 10CFR20 Not Yet Realized

- Increased Worker Safety

- Increased Worker Efficiency

- Potential Cost Savings

Biggest Rad Worker Concern was/is internal Exposure

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Lessons Learned

Needed To Maximize RP Technician involvement and Review i

Needed To Use in-House Personnel For Ownership

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Needed To Maintain Consistency Across Procedure Set

Needed To Establish Technical Bases To Keep Program Integrity l

Problem Areas

Lack of Revised /New Reg Guides

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Proaram Evaluation

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Established Self Assessment Program QPD Surveillances and Annual Audits Special QPD Outage Surveillance Semi-Annual Data Review

- Personnel Contaminations

- RIRs

- QPD Trend Data

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t 1993 REFUELING SHUTDOWN

,

START DATE:

JULY 31,1993 DURATION:

8 WEEKS TOTAL WORK ACTIVITIES PLANNED:

>1650 TOTAL "HOl' SIDE" WORK ACTIVITIES:

>1000

.

RWP'S PLANNED:

> 390 i

!

f

>

SEN93061

.

i i

1993 REFUELING SHUTDOWN t

SIGNIFICANT HOT SIDE WORK PLANNED i

r CHALLENGING ALARA GOALS ENHANCED REFUELING PREPARATIONS

,

i SEN93061

!

.

,

HOT SIDE WORK PLANNED

'

CORE BARREL THERMAL SHIELD

,

EDDY CURRENT TESTING THREE STEAM GENERATORS ISI/IST PROGRAM LETDOWN ISOLATION VALVE REPLACEMENT WIDE RANGE NUCLEAR INSTRUMENTATION REPLACEMENT MOV WORK

" HOT SPOT" PIPE REPLACEMENTS CORE REFUELING REACTOR COOLANT PUMP REPAIRS

SEN93061

.

l

-

l REFUELING PREPARATIONS

!

HELD RAD PROTECTION STAFF PRE-REFUELING MEETINGS I

ESTABLISHED REFUEllHG PERFORMANCE GOALS ENHANCED PLANNING PROCESS / WORK ORDER PROCESS CONSOLIDATED ALARA FUNCTION EXPANDED RAD WORKER TRAINING HEIGHTENED RAD WORKER EXPECTATIONS RETAINED HIGHLY QUALIFIED CONTRACTOR STAFF UTILIZE SOURCE TERM SAVING TECHNIQUES DEMONSTRATED IN PAST REFUELINGS:

EARLY BORATION COOLDOWN

-

RWST CLEANUP

-

SHIELDING PROGRAM

-

ETC.

-

SEN93061

-

.

.

>

RADIATION PROTECTION ENHANCEMENTS t

DEPARTMENT NIGHT ORDERS ENHANCED TECHNICIAN TURNOVER PROCESS DEVELOPED CONTRACTED TECHNICIAN EXPECTATIONS

!

DEVELOPED AND PRESENTED EXPECTATIONS SUMMARY FOR RAD WORKERS

.

EXPANDED USE OF TELEDOSIMETRY, VIDEO, AND REMOTE COMMUNICATION EQUIPMENT

,

EMPHASIZED MANAGEMENT'S ENDORSEMENT OF RAD WORKER'S EXPECTATIONS I

SEN93061

..

- -

- - -

-

-

.

_.

_

_

_

._.

_

..

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RAD PROTECTION REFUELING GOALS

'

,

}

NO PERSONNEL EXPOSURE BEYOND l

ADMINISTRATIVE / REGULATORY LIMITS l

ADMINISTRATIVE LIMIT: s1 REM / YEAR

-

.

NO UNPLANNED EXPOSURE

l I

TOTAL STATION DOSE: <396 PERSON REM L

!

!

CONTAMINATED FLOOR SPACE: <5000 FT

i

'

RAD WASTE GENERATED: <6500 FT

}

-!

!

.

f s_,

.

'

REFUELING CONTRACTED STAFF JOB COVERAGE CONTRACTED STAFF:

1 SITE COORDINATOR 8 HP SUPERVISORS 90 HP SENIOR TECHNICIANS 6 HP JUNIOR TECHNICIANS 105 TOTAL QUALIFICATION SUMMARY:

'

ALL SENIOR HP TECHNICIANS - ANSI 18.1

-

87Property "ANSI code" (as page type) with input value "ANSI 18.1</br></br>-</br></br>87" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. OF 90 SENIOR HP TECHNICIANS - ANSI 3.1

-

,

9 SENIOR HP AND ONE SUPERVISOR - NRRPT

-

PRIOR MAINE YANKEE EXPERIENCE:

ALL SUPERVISORS

-

47 SENIOR HP TECHNICIANS

-

5 JUNIOR HP TECHNICIANS

-

SITE COORDINATOR 20 YEARS NUCLEAR EXPERIENCE

,

-

i PREVIOUS M.Y. EXPERIENCE

-

PROVEN TO BE AN EFFECTIVE MANAGER

-

SEN93061

.

.

LOW LEVEL RAD WASTE UPDATE

.

TEXAS COMPACT NEGOTIATIONS WASTE GENERATION GOALS WASTE MINIMlZATION PROCESS SEN93061

-

-- -

.

.

TEXAS COMPACT NEGOTIATIONS - YEAR IN REVIEW MAINE BEGAN NEGOTIATIONS LATE '91

(PUBLIC ADVOCATE)

TEXAS LEGISLATURE APPROVED MAY '93 COMPACT BILL MAINE LEGISLATURE APPROVED JUNE '93 COMPACT BILL TEXAS / MAINE GOVERNORS SIGNED JUNE '93 BILLS MAINE REFERENDUM TO ACCEPT NOV. '93

'

COMPACT SEN93061

.

'

RAD WASTE MINIMlZATION PROCESS CONTROL THE UNNECESSARY CREATION OF WASTE ELIMINATE UNNECESSARY PACKING MATERIALS

-

CONTROL THE MIGRATION OF TOOLS / EQUIPMENT TO THE

-

PRIMARY SIDE EFFECTIVELY USE WASTE PROCESSING SYSTEMS

-

MINIMlZE WASTE THROUGH REVIEW OF WORK PACKAGES AND

MATERIAL CONTROL PERMITS MET WITH PROJECT LEADERS BEFORE THE REFUELING

-

<

EXPANDED CONTAMINATION CONTROL TECHNIQUES FILTERED DRAINING

-

REDUCED CONTAMINATED AREAS

'

-

PROMPT RESOLUTION OF PRIMARY SIDE LEAKS

-

EXPANDED USE OF INCINERABLE MATERIALS EXPANDED USE OF LAUNDERABLE MATERIALS TOOL / EQUIPMENT BAGS

-

PROTECTIVE CLOTHING

-

CONTINUED MONITORING OF WASTE STREAMS

-

SEN93061

.

l

.

_RA_D WORKER EXPECTATIONS

,

.

EXAMPLE QUESTIONS

,

WORKER AWARENESS

,

!

!

1.

What is Your RWP Number?

2.

Where are You Going to Perform Your Work?

3.

What Work Activity are You Going to Do (specific

to each individual)?

I 4.

What is Your Dose Limit and the Dose Rates in

>

Your Work Area?

,

!

5.

Where are the " Hot Spots" located, and the

" Low Dose Waiting Areas" for Your Work Evolution?

Workers Who Are Not Able to Demonstrate Adequate Knowledge of the Above Will be Denied Access

GDP93056 l