IR 05000335/1980006
| ML17209A271 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/23/1980 |
| From: | Gibson A, Hosey C, Lacey L, Stohr J, Zavadoski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17209A266 | List: |
| References | |
| 50-335-80-06, 50-335-80-6, NUDOCS 8010240539 | |
| Download: ML17209A271 (62) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report No. 50-335/80-06 Licensee:
Florida Power and Light Company Miami, FL 33101 Facility Name:
St. Lucie Unit jul Docket No. 50-335 License No. DPR-67 Inspection at:
St.
L cie Site, Hutchinson Island, Florida Inspectors:
lV
~ R.
W. Zav d ki C.
M. Hos y L. R. Lacey Accompanying Personnel:
L. Munson, Battelle Northwest L. Faust, Battelle Northwest Approved by:
A. F. Gibson, Section Chief, Fuel Facility and Mater als S
ety Branc Date Signed 6lzs(co Date Signed Gl~ggo Date Signed 4 (@o/SO Date Signed J.
Ph'
S ohr, C
ef, Fuel acility and terials Safety Branch D te Signed SUMMARY Inspection Date:
March 10-21, 1980 Areas Inspected This special announced inspection involved 487 inspector-hours onsite in the area of health physics appraisal including organization, qualifications, training procedures, ALARA programs, external exposure control, personnel dosimeter program, internal dosimetry, respiratory protection, medical emergencies, instru-mentation, surveillance and access control, radwaste control, facilities and equipment, re-entry, and in-plant systems.
Results:
Of the 16 areas inspected, no items of noncompliance or deviations were identified in 12 areas; 4 items of noncompliance were found in 4 areas soxomco'3g
(Infraction:
Failure to have a retraining program (paragraph 6. d)
(50-335/
80-06-08); Infraction:
Failure to follow procedures (paragraphs 7.c(3),
9.g, 12.j, 12.k, 12.l, 12.n, 14.c, and 15.i) (50-335/80-06-13);
Infraction:
Failure to take adequate samples of breathing air (paragraph 12.0)
(50-335/80-06-15);
Infraction:
Contaminated tool control (paragraph 15.c) (50-335/80-06-18)).
DETAILS Persons Contacted Licensee Employees-K.
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Harris, Assistant Manager, Power Resources Nuclear, Corporate Wethy, Plant Manager, St. Lucie Barrow, Operations Superintendent, St. I.ucie Dillard, Assistant Plant Superintendent, St. Lucie Vaux, QC Supervisor, St. Lucie Buchanan, Health Physics Supervisor, St. Lucie Hughes, Health Physics Supervisor, Turkey Point Story, Corporate Health Physicist Mercer, Assistant Health Physics Supervisor, St. Iucie Perle, Corporate Health Physics McCullers, Health Physics Operations Coordinator, St. Lucie Essinger, QA Operations Assistant Manager, Corporate Bailey, QA Operations Supervisor, St. Lucie Roos, Quality Control, St. Lucie Walls, Quality Control, St. Lucie Jennings, Technical Supervisor, St. Lucie Baker, Health Physics Administration Coordinator, St. Lucie Green, Health Physics, Training Coordinator, St. Lucie Bell, Health Physics, Radwaste Coordinator, St. Lucie Large, Health Physics, RPM, St. Lucie Barrier, Health Physics, RPM, St. Iucie Hernandez, Health Physics, RPM, St. Lucie Frechette, Chemistry Supervisor, St. Lucie Cox, Chemistry Technician, St. Lucie Ward, Operations Trainee, St. Lucie O'Niel, Operations Trainee, St. Lucie Roberts, Operations Trainee, St. Lucie Other licensee employees contacted during this inspection included
construction craftsmen, 35 technicians, 8 operators, 16 mechanics,
security force members, and 12 office personnel.
"=Attended exit interview.
Exit Interview The inspection scope and findings were summarized on March 21, 1980 with those persons indicated in Paragraph 1 above.
The inspectors reviewed and examined all aspects of the health physics program at the facility.
This examination included organization, staffing, audits, procedures, training, retraining, exposure control, instruments, access control, AIARA, rad waste, surveys and facilities.
The inspectors stated that the areas of staffing, retraining, and the ALARA programs should be reevaluated by the licensee; the licensee agreed to consider a reevaluation.
At the exit interview the
inspectors also identified items of noncompliance which included:
(1)
inadequate retraining program for health physics personnel (discussed in paragraph 6.d.);
and (2) contaminated tools outside the controlled area (discussed in paragraph 15.c.); (3)failure to follow procedures (paragraphs 7.c.(3), 9.g., 12.j., 12.1.,
12.n.,
14.c.,
and 15.i.); and (4) failure to provide respirable air of approved quality (paragraph 12.0).'he plant manager acknowledged the items of noncompliance.
Listing of Unresolved Items, Noncompliance and Inspector Follow-up Items The following is a
summary tabulation of all the unresolved items, non-compliance and inspector follow-up items identified throughout this report.
Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
New unresolved items identified during this inspection are discussed in paragraph 16.a.
Inspector follow-up items (IFI) are matters which the NRC desires to look into again and which will be examined in future inspections.
IFI (50-335/80-06-01)
Reporting recommendations for health physics super-visor (paragraph 4.a.).
IFI (50-335/80-06-02)
Establishing a formal group with the sole responsi-bilityof ALAI@, (paragraph 4.c.).
IFI 50-335/80-'06-03)
Focusing the corporate health physics activities on the plants (paragraphs 4.d.
and 4.e.).
IFI (50-335/80-06-04)
Evaluation of the present staffing requirements for the health physics group (paragraph 4.f.).
IFI (50-335/80-06-05) In-depth performance audits (paragraph 4.h.).
IFI (50-335/80-06-06)
Increasing the ratio of supervision to temporary employees (paragraph 5.d.).
IFI (50-335/80-06-07)
Lack of technical depth (paragraph 5.f.).
Noncompliance (50-335/80-06-08) Failure to have a retraining program (para-graph 6.d.).
IFI (50-335/80-06-09)
Requirements for Health Physics Manual (paragraph 7.b.).
IFI (50-335/80-06-10)
Revise Procedures (paragraph 7.c.
and 14.c.)
IFI (50-335/80-06-11)
Establishment of a formal ALARA program (paragraphs S.a.,and S.b.).
Unresolved (50-335/80-06-12)
Comparison of pocket dosimeter and TLD readings (paragraph 9.d.).
Noncompliance (50-335/80-06-13)
Failure to follow procedures (paragraphs 7.c.(3), 9.g., 12.j., 12.k., 12.1., 12.n., 14.c.,
and 15.i.).
IFI (50-335/80-06-14)
Training and documentation of training for cleaning of respirators (paragraph 12.i.).
Noncompliance (50-335/80-06-15) Failure to take adequate samples of breathing air (paragraph 12.o.).
IFI (50-335/80-06-16)
Dose assessment for personnel contamination (para-graph 12.r.).
IFI (50-335/80-06-17)
Establishment of a formal training and qualification program for instrument technicians (paragraph 14.b.).
~ Noncompliance (50-335/80-06-18)
Contaminated tool control (paragraph 15.c.).
IFI (50-335/80-06-19) Air sample results for pressurizer cubicle (paragraph 15.h.).
Unresolved (50-335/80-06-20)
Setpoints for waste gas monitor (paragraph 16.a.).
4.
Organization The inspectors reviewed the organizational structure of the plant.
Figure
shows the overall plant organization and figure 2 shows the health physics organization.
Figure 1 shows that the normal reporting chain for the health physics supervisor to be through the operations superintendent to the plant manager.
The dotted line for the health physics supervisor to the plant manager allows the health physics supervisor to go directly to the plant manager should the need arise.
The technical, quality control, security and maintenance supervisors, startup, operations and Unit 2 construction superintendents, the outage coordinator and the power resources team leader all report to the plant manager.
At the St. Lucie facility, the health physics supervisor has always reported through the operations superintendent.
The inspectors pointed out that Regulatory Guide 8.8, March 1977, Revision 2, section C.1.b.3, recommends that "The Radiation Protection Manager (RPM) (onsite) has a safety-related function and responsibility to both employees and management that, can be best fulfilled if the individual is independent of station divisions, such as operations, maintenance, or technical support, whose prime responsibility is continuity or improvement of station operability".
No conflicts due to health physics reporting through operations were ascertained by the inspectors, however this may be strongly dependent on the people involved.
Therefore, in their professional judgement, the inspectors recommended a reporting chain of the health physics supervisor directly to the plant manager (IFI 50-335/80-06-01).
The inspectors also noted that the chemistry and health physics functions were split at the facility, thereby not diluting the health physics effor b.
The organization of the health physics group is shown in Figure 2.
The entire department presently consists of 12 people and is authorized 14.
The health physics administration coordinator is responsible for gathering and posting all the required records for dosimetry, qualifi-cations, training and respiratory protection, as well as plant survey records.
The health physics operations coordinator is responsible to see that the day-to-day operations in the plant are adequately covered.
He is also responsible for seeing that required surveys are taken, instruments are calibrated, and respirators are cleaned and surveyed.
The training coordinator is responsible for all the health physics training including "red badge" training and respiratory training.
The radioactive waste coordinator is responsible for disposal and reduction of solid wastes generated at the facility.
The direct responsibility for liquid and gaseous wastes lies in the chemistry department.
At present, the radioactive waste coordinator also acts as the special projects coordinator.
c ~
The inspectors noted that there was no formal structure within the organization which had overall responsibility for ALARA (i.e., main-taining plant personnel radiation exposures as low as reasonably achievable).
From discussions with the plant manager, the health physics staff and other plant personnel, and through direct observation, the inspectors concluded that some elements of an ALARA program were present and functional.
Based on their professional judgement and observations, the inspectors recommended the establish-ment of an ALARA coordinator with sole responsibility for implementing ALARA programs and unemcumbered by other responsibilities (IFI 50-335/
80-06-02).
Additional findings and comments on the ALARA program at St. Lucie are discussed in detail in the ALARA section of this report.
d.
The inspectors also reviewed the organization of the corporate health physics program.
Figure 3 represents the organizational structure of FPGL's corporate health physics program.
There are presently 5 members of the staff involved in health physics.
At least two people devote full time to the TLD reading system.
The remainder devote the majority of their time on other matters not directly related to plant health physics, such as the licensing of the proposed steam generator replace-ments at Turkey Point.
The corporate health physicists have a goal for 1980 of evaluating the ALAMprogram at the plants and at corporate, but thus far have been unable to do so.
e.
Communications at the facility seemed adequate within the plant health physics staff. It was also apparent that considerable health physics preparation had been made for the outage which started March 14, 1980.
The inspectors noted some instances where communications appeared to be a problem.
For instance, from discussions with licensees'epre-sentatives the inspectors found that the site health physics group had no input into the redesign of the boric acid valve stations, even though boric acid leaks can potentially represent significant radio-logical problems.
In general, the inspectors noted a lack of health physics input into maintenance procedures and preplanning operations.
'ealth physics personnel became aware of most maintenance jobs when
the workers and foreman appeared at the health physics operations window and requested a
completed radiation work permit.
Further, communications between the plant and corporate were not found to be very responsive.
The inspectors were told by licensees'epresenta-tives that it was not uncommon for corporate to take days to respond to a
simple telephone call.
Based on the observed communications practices, the inspectors recommended that the function of the corporate health physics group be more dedicated to the needs of the plant (IFI 50-335/80-06-03).
At present health physics coverage is not provided all weekend.
The plant relies on operators who have been cross-trained in health physics to provide normal health physics coverage over the weekend.
According to licensee's representatives, the present permanent health physics staff, comprised of 12 individuals, is not adequate for weekly round-the-clock health physics coverage.
Licensee's representatives also stated that the average health physics department overtime load was 700 working hours for 1979.
At present, there is no clerical help permanently assigned.
Instead, technicians, who might be better utilized elsewhere, do the routine sorting and filing of surveys and personnel dosimetry data.
Licensee's representatives stated they are presently engaged in esti-mating the manpower requirements for the site and have not as yet come to a conclusion.
The inspector stated that another FPSL dual unit nuclear facility had a permanent health physics staff of 30 permanent employees.
The overall function and records keeping requirements of both FPSL sites are nearly identical, particularly during operations.
The inspectors also found there was inadequate time to devote to retraining of permanent plant employees because of inadequate staffing (see paragraph 6.d.).
The inspectors were told by licensee represen-tatives that staffing requirements were being evaluated and that additional data available from other plants would be considered (IFI 50-335/80-06-04).
The health physics program at the site is audited by the corporate health physics group.
The review entails a review of procedures and practices at the facility.
The corporate audit program was described by licensee's representatives as predominately a procedural audit and not a performance audit.
Based on observations of the audits conducted and the contents of the audits, the inspectors stated that, in their professional judgement, performance audits as well as procedural audits should be conducted and could be accomplished with either in-house personnel or outside independent contractors (IFI 50-335/80-06-05).
Plant Procedure QI 18-PR/PSL-2, Quality Control Surveillance estab-lishes a quality control surveillance at the plant which includes health physics activities.
Technical Specification 6.5.2.8 lists the audits of the plant that shall be performed under the cognizance of the company Nuclear Review Board (CNRB).
These audits are performed by a
group on-site that do not report to the plant manager.
The
inspectors discus'sed the audit and surveillance program related to radiation protection with licensee representative and reviewed audits and surveillance performed in 1979.
The inspector stated that the surveillances appeared to be superficial in the health physics area and did not include a review of gaseous and liquid waste releases during 1979.
The surveillances tended to concentrate in the areas of radioactive waste shipments and housekeeping in the RAB.
The frequency and scope of followup action on audits related to the radiation protec-tion program appeared to be adequate.
The inspectors found the organization at the St. tucie facility to be acceptable.
Based on the inspectors'rofessional judgement, improve-ments to the organization of the health physics program could be obtained if licensee consideration is given to (1) changing the report-ing chain of the health physics supervisor (paragraph 4.a.);
(2)
establishing a group with the sole responsibility of ALARA (paragraph 4.c.);
(3)
focusing the corporate health physics activities on the plants (paragraphs 4.d.
and 4.e.);
(4) evaluating the present staffing level and utilizing the staff to its optimum potential (paragraph 4.f.) and (5) performing performance, as well as procedural, audits of the health physics program (paragraphs 4.g.
and 4.h.).
5.
(}ualifications
~
~a.
Unit 1 Te chnical Spec'ification 6.3.1 states that,
"Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18,1-1971 for comparable positions, except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975."
Paragraph 4.5.2 of ANSI N18.1-1971 states in part that,
"Technicians in responsible positions shall have a
minimum of two years of working experience in their specialty."
Regulatory Guide 1.8, September 1975 states in part that,
"The RPM should have a bachelor's degree or the equivalent in a science or engineering subject... should have five years of professional experi-ence in applied radiation protection....
At least three years of this professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power stations b.
c ~
The plant Radiation Protection Manager's qualifications were evaluated against the recommendations found in Regulatory Guide 1.8, September 1975.
All ll members of the permanent staff appeared to meet the requirements of Paragraph 4.5.2, ANSI N18.1-1971 (see Table 1).
The four first-line supervisors (Senior Plant Technicians)
had an average of approximately 4.8 years experience and 2.0 years formal training.
The Radiation Protection Manager was found to meet or exceed all the recommended qualifications in Regulatory Guide 1.8, September 1975.
- An inspector evaluated the technical qualifications of ll individuals on the permanent health physics staff, 20 contractor supplied senior health physics technicians, and two health physics technicians on loan from another utility.
The inspector reviewed available resumes and
-7-personnel records in addition to interviewing selected individuals.
The qualifications of approximately 24 contractor supplied junior health physics technicians and decontamination personnel present for the outage were not evaluated, as the licensee stated that they would not be placed in responsible positions and would be closely supervised.
All individuals were evaluated against Paragraph 4.5.2 of ANSI N18.1-1971.
The evaluation of contractor supplied personnel presented a
problem in that three obvious and conflicting methods of meeting the two-year experience requirement exist.
First, two years may be interpreted calendar years (giving no credit for overtime).
Second, two years may be interpreted as 4000 working hours (giving full credit for overtime).
A third method, allowing no more than 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> to be credited in a 40 week period, was also employed.
The plant utilizes a
4000 working hour criteria plus written evaluation by senior health physics personnel.
The two health physics technicians on loan from another utility were also found to meet Paragraph 4.5.2, ANSI N18.1-1971 requirements (see Table 2).
However, of the 20 contractor-supplied personnel evaluated, only nine (45@ had two calendar years of experience, 13 (65/) appeared to meet the
"no more than 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> in 40 weeks" criteria, and all but one (95@ had over 4000 working hours of experience.
All designated senior health physics technicians were found to meet the criteria estab-lished by the plant.
The twenty contractor-supplied personnel averaged 2.0 years of formal training, 3.8 calendar years of experience, and 10,500 working hours experience.
However, if the five most experienced individuals are deleted, the averages for the remaining fifteen become 1.7 calendar years of experience and 5,500 working hours experience.
The inspectors reviewed the adequacy of supervision of contractor supplied personnel by the permanent health physics staff.
There are approximately 45 contractor-supplied individuals on board for radiation protection or decontamination work, few of whom have a significant amount of plant specific knowledge.
The licensee stated that the supervisory responsibility for these 45 individuals was primarily divided between three of the permanent staff, the outage coordinator (Senior Plant Technician)
and the day shift and night shift super-visors (both radiation protection men) with occasional support from the remaining three radiation protection men.
Also, the decontami-nation personnel were supervised by contractor supplied junior health physics technicians, who reported in turn to the appropriate shift supervisor.
The licensee further stated that some of the contractor supplied personnel were assigned jobs requiring minimal supervision.
The inspectors stated that, in their professional opinion, the super-visor-worker ratio appeared low, considering that temporary employees were involved and that the two shift supervisors had minimal supervisory training or experience (IFI 50-335/80-06-06).
This problem is also discussed in paragraph 1 e.
The inspectors expressed a concern that the present permanent staff of 11 technical persons, two of whom may be considered at the management level, would be inadequate to respond to a major radiological emergency, particularly since one or more individuals would probably not be available at any given time and health physics coverage is not provided on weekends.
The licensee stated that support personnel would be obtained from the General Office and from Turkey Point in a matter of hours.
The inspectors stated that these individuals may be of limited value due to the lack of plant specific knowledge and/or experience (IFI 50-335/80-06-04).
Based on their professional judgement and observations, the inspectors expressed their concern of the lack of technical depth found amongst the permanent staff Only two individuals had bachelors degrees.
During the course of their review, the inspectors found that the loss of the computer system for the whole body counter and the GeLi analyzer halted the analysis of whole body counts and air sampling analysis even though the spectrum on both analyzers was available.
The inability to analyze the whole body counter spectrum caused delays in processing workers into the plant and the inability to analyze the GeLi spectrum for air samples caused delays in jobs requiring air sample results.
Further discussions on the manual reduction of spectra are included in paragraph ll.a. of this report.
The inspectors also noted that the training given to technicians for the calibration of instruments lacked technical depth and is discussed more thoroughly in paragraphs 14.b and c of this report.
Technical depth and expertise is needed at any facility to understand the multitude.of fixed and portable instruments, and their anticipated response, system's manipulations and overall regulatory requirements.
Based on their findings and observations, the inspectors recommended that the technical depth of the health physics staff be enhanced (IFI 50-335/80-06-07).
g The inspectors found the licensee's health physics qualification program to be acceptable.
However, the inspectors recommended to the licensee that improvements in their program could be obtained by (1)
defining their method of meeting the ANSI N18.1 and Regulatory Guide 1.8 (paragraph 5.c.);
(2)
increasing the ratio of supervision to technicians (paragraphs 5.d.
and 5.e.);
and (3) increasing the tech-nical depth of the health physics staff (paragraph 5.f.).
6.
~Trainin a
~
Technical Specification 6.4 states that a retraining and replacement training program for the facility shall be maintained under the direction of the Training Supervisor and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.
Plant Procedure QI 2-PR/PSL-2, Revision 7, Indoctrination and Training of St. Lucie Plant Personnel, specifies the training/retraining requirements for plant personne An inspector attended portions of the radiation controlled area access training and retraining courses given to contract workers and the plant staff, discussed the training with licensee representatives and reviewed selected training records for vendors and the plant staff.
The radiation controlled area access training provided the minimum information required to be presented to radiation workers by
CFR 19 '2, as well as valuable site specific information.
The individuals attending the training courses were required to pass a written exami-nation to receive credit for the course.
The inspector reviewed selected training records of the plant staff and determined that the individuals had recieved the biannual radiation control area access retraining required by plant procedures.
An inspector attended portions of the training sessions presented to the contract health physics technicians and decontamination personnel who were brought on site to supplement the plant's health physics organization during the refueling/maintenance outage and discussed the training with licensee representatives.
The course consisted of approximately two days of classroom training, which included site specific radiation protection training, required of all plant workers and a review of plant procedures, and approximately one day of in-plant familiarization.
A written examination was administered to the health physics technicians at the conclusion of the training to measure the technician's knowledge of basic health physics principles.
The scope and depth of the material covered appared to be adequate to ensure that the technicians are familiar with the plant's approach to radiation protection.
ANSI N18.1-1971 states that a training program shall be established which maintains the proficiancy of the operating organization.
The licensee's Health Physics Manual, Paragraph 3.3,2 specifies that health physics personnel shall complete an orientation and qualification program as directed by the health physics supervisor.
Paragraph 3.3.3.2.3.c states that individuals are required to satisfactorily complete refresher courses no less than once every two years.
An inspector discussed the training/retraining program for health physics technicians (designated radiation protection men and senior plant technicians by the licensee) with a licensee representative and reviewed the training records of all technicians.
The inspector also discussed the plant's training/retraining program with several permanent health physics technicians.
Although Plant Procedure QI 2-PR/PSL-2 assigns the responsibility to the training supervisor for ensuring that plant training meets the requ'irements of the technicial specifi-cations and assigns to thy health physics supervisor the responsibility for ensuring that adequate health physics training is conducted, a
training/retraining program for health physics technicians is not in effect at the plant.
The training records for 12 permanent health physics technicians were reviewed by the inspector.
Only two had completed the Health Physics Technician Qualification Check-Off (involving a
review of
-10-Health Physics Procedures and an oral examination).
Technicians interviewed indicated that the training/qualification program started in 1979 and was discontinued after a review of ten procedures because of the heavy workload.
The technician who currently calibrates health physics survey instruments had no formal certification that he had demonstrated proficiency in calibrating instruments, nor had other technicians who had performed calibrations.
Some training had been performed in 1979 for some technicians in the area of Department of Transportation regulations for shipping low level radioactive waste, Ge-Li analysis of samples and operation of the whole body counter.
However, oral/written examinations results had not been documented and maintained as required by the licensee's Health Physics Manuals The inspector stated that a formal training program should be established to provide a training/qualification program for replacement personnel and a retraining program designed to increase the technical competence of the health physics technicians and to ensure that the proficiency of the health physics staff is maintained.
The retraining program should include as a minimum the following elements:
(1)
established frequency (i.e., annually)
(2)
minimum number of hours required (3)
areas to be covered (i.e., health physics problems in industry, lessons-learned from major jobs at the plant, new regulations, fundamental health physics principles and review of new procedures).
(4)
Documentation of attendance, subjects covered, length of training session, examinations given and results.
Discussions with the training supervisor revealed that he did not take an active part in the training and retraining of health physics techni-cians nor did he ensure that the training they received met the require-ments of technicial specifications.
A licensee representative acknowledged that the plant did not have a formal training/qualification program.
He further stated that the workload and staff size contributed significantly to the lack of training.
The inspector stated that failure to have a retraining program which maintained the proficiency of the health physics technicians was in noncompliance (50-335/80-06-08) with Technical Specification 6.4.1.
Plant Procedure HP-1, Radiation Work Permit, authorizes the nuclear plant supervisor (NPS) to approve radiation work permits for health physics when health physics personnel are absent from the site.
An inspector evaluated the scope and depth of the health physics training received by the NPS by discussing the program with licensee representa-tives, reviewing radiation work permits where the health physics authorization was signed by the NPS and by reviewing the material used in the training program.
The licensed operators receive approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of classroom health physics training using a text prepared by a consultant and are required to pass a comprehensive written examination
-11-covering health physics.
In addition, they spend approximately three days with the health physics staff receiving training in the practical aspects of a radiation protection program.
The radiation work permits reviewed by the inspector for which the health physics authorization was signed by an NPS appeared to give adequate consideration to radia-tion protection matters.
The inspectors found the training program for health physics technicians and general employees at the St. Iucie facility to be adequate, but recom-mended improvelnents to the retraining program for health physics tech-nicians.
Paragraph 5.2.d.
discusses the required improvements and considerations necessary to make the retraining program acceptable.
7.
Procedures a
~
Section 6.11 of the technical specification states
"Procedures for personnel radiation protection shall be prepared consistent with the requirements of
CFR Part
and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
Based on the above the inspectors reviewed a current copy of the Health Physics Manual and set of procedures for the St. Lucie facility.
b.
The inspectors reviewed the Health Physics Manual dated April 18, 1977, Revision l.
In the inspectors judgement, the manual covers all the elements of a good health physics program and is reasonably current.
However, the inspectors noted some areas where the manual could be improved.
The manual defines the licensee's definition of ALARA and provides general guidelines of ALARA philosophy throughout the document.
However, specific instructions in the manual for implementation of ALARA principles are provided primarily as recommendations.
For example, Section 3.5 of the Health Physics Manual states:
"New nuclear facility designs should be reviewed by corporate Health Physics for adequate shielding and personnel radiological facilities." and, further,
"Design changes and/or modifications for existing facilities, or those under construction, that may affect personnel radiation exposures, should be reviewed by Corporate Health Physics prior to implementation".
In the inspectors judgement, the implementation of ALARA principles in the manual should be stated as requirements (IFI 50-335/80-06-09).
c'he following procedures were reviewed by the inspectors:
HP 4 HP 6 HP 10B HP 10C HP ll HP 12 HP 13A Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
Radiation Work Permits Scheduling of Health Physics Activities Step-off Pads NMC Automatic Sample Counter Calibration and Operation of the MCA Portal Monitor Operation Check Calibration, Operation of TLD Reader Operation of Portable Survey Instruments
"12-HP 13C Rev.
HP 13D HP 14E HP 14F HP 20 HP 22 HP 34 HP 41 HP 43 Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
HP 44 Rev.
Rev.
Rev.
Rev.
HP 62 ~
Rev.
Rev.
HP 71 Rev.
HP 66 Rev.,
HP 67 Rev.
HP 70 Rev.
Calibration of Portable Gamma Survey Instruments Calibration of PNR-4 Use of Eberline MSGC"1000 Calibration of Radeco Air Sampler Radiation and Contamination Surveys Air Sampling Estimating Beta Skin Dose From Noble Gases Movement of Material and Equipment Leak Testing 6 Inventory of Radioactive Sealed Sources Calibration of the NMC Portable Air Monitor-NMC Model AM-331F Protective Clothing Requirements Portable Shielding Respiratory Protection Manual Selection and Use of Respiratory Protection Equipment Inspection, Maintenance and Quality Assurance of Respiratory Protection Equipment Maximum Permissible Concentration Hour Accountability Cleaning, Disinfection, Decontamination, Inspection and Storage of Respiratory
~ Protection Equipment Respirator Fitting Respiratory Protection Training Personnel Decontamination of Tools, Equipment and Areas Decontamination of Tools, Equipment and Areas The inspectors recommended the following changes be made to strengthen some of the procedures:
(1)
Health Physics No.
10B, Revision 1 -
NMC Automatic Sample Counter - Paragraph 8.2.5.3, requires a
1-minute count (60 HZ source)
monthly.
The inspectors
'suggested it be done weekly (IFI 50-335/80-06-10).
(2)
Health Physics No.
10C, Revision 4 - Calibration and Operation of the MCA and Health Physics No. 31, Revision 4 - Calibration and Operation of the In-Vivo Bioassay System.
The inspectors suggested that these procedures should include samples of and descriptions of how to evaluate the data in the event the computer fails but the MCAs operate.
(IFI 50-335/80-06-10)
(3)
Health Physics No.
12, Revision 4 - Calibration, Operation of TLD Reader - The inspectors suggested that the annual calibration for the TLD reader was too infrequent for the current use of the reader and suggested more frequent calibration.
In addition, Health Physics No.
12, Revision 4,
Calibration, Operation of TLD Reader - The inspectors noted that the procedure reqqires
-13-an annual calibration.
Due to changes in photomultiplier tube characteristics and coating on the window, a TLD reader, even if left on, must be recalibrated prior to use for personnel dosimeter readings and checked every 20 or so readings to assure consistent response.
The inspectors recommended that the procedure should be changed to provide these controls.
In addition, the procedure states that 10/ of the TLD chips are to be set aside, labeled and used for controls, but does not specify their storage location.
The 'inspectors recommended that TLDs used for background determi-nation of personnel dosimeters should be stored at the same location as the personnel dosimeters and that the procedures should reflect-this.
(Noncompliance 50-335/80-06-13).
Health Physics No.
13A, Revision 0, Operation of Portable Survey Instruments -
The inspectors recommended that the procedure be revised to include the range of acceptable response when func-tionally checked on a check source before each use and to specify the appropriate alarm/set point for the Model RM-17 when used at Frisker locations.
(IFI 50-335/80-06-10)
Health Physics No.
13C, Revision 2, Calibration of Portable Gamma Survey Instruments - The inspectors recommended that the calibra-tion values be limited to +10/ and not +20/.
(IFI 50-335/80-06-10)
Health Physics No.
14E, Revision 0 - Use of Eberline MSGC-1000-The inspectors recommended that the procedure should include instructions on placement of instrument to be calibrated since that is critical to a
reasonable calibration.
(IFI 50-335/
80-06-10)
Health Physics No.
34, Revision 2 - Estimating Beta Skin Dose from Noble Gases - This procedure does not say how one is to know what radionuclides are present even though this information is needed to use the graphs or equations provided.
The inspectors recommended that the information be provided.
(IFI 50-335/
80-06-10)
Procedure HP 41, Revision 2 - Movement of Material and Equip-ment - This procedure authorizes the Nuclear Plant Supervisor or his designee to monitor and release selected equipment when health physics personnel are absent.
Considering that HP personnel are not scheduled, in plant for approximtely 30$ of the time during normal operations, this practice appears to negate the stated purpose of the procedure:
"To provide a
means by which Health Physics can exercise positive control of materials and equipment entering and leaving the Radiation Control Area" as well and appears inconsistent with good health physics practice.
(IFI 50-335/80-06-10)
-14-(9)
Health Physics 44, Revision 1 - Calibration of NMC Portable Air Monitor -
NMC Model AM 331F - The procedure calls for annual calibration.
The inspectors feel this is too infrequent and recommended monthly, but as a minimum quarterly, calibration or after maintenance and before refueling outages.
(IFI 50-335/
80-06-10)
Health Physics 60, Revision 4 - Respiratory Protection Manual-The inspectors recommend that criteria for medical evaluation be defined and that certain basic requirements be established, i.e.,
lung capacity, blood pressure, and other criteria used.
(IFI 50-335/80-06-10)
Health Physics 62, Revision 2 - Inspection, Maintenance and equality Assurance of Respiratory Protection Equipment.
The inspectors noted that in Section 8.3, the procedure instructions are not adequate to assure that breathing air meets the require-ments of CGA Specification G-7.1-1966 for grade D breathing air.
Also, the procedure is out of date in that HP Form 62 is no longer used.
In addition, the procedure requires unique numbering and record maintenance for "Each SCBA unit, supplied air suit and separate manifolds, hoses, face pieces and supplied air breathing regulations."
The inspectors "observed that unique numbering and records are maintained only on SCBA units.
Further, the criteria for establishing
"thoroughly trained" and "trained" used in the procedure should be defined.
(IFI 50-335/80-06-10)
Health Physics 65, Revision 1 - Cleaning, Disinfection, Decontami-nation, Inspection and Storage of Respiratory Equipment - In Section 8.1.6.3, the inspectors recommended that the maximum acceptable dose rate should be stated, as well as the method to be used for averaging.
(IFI 50-335/80-06-10)
Health Physics 70, Revision 2 - Personnel Decontamination Procedure.
The inspectors found the procedure to be inadequate in providing appropriate instructions and precautions for decontamination of personnel.
Good health physics practices dictate that'econtami-nation of body skin areas should be discontinued unless under medical supervision where skin sensitivity or reddening of the skin occurs from decontamination efforts.
The procedures does not provide instructions for consultation wth medical personnel except in cases of eye, nose and mouth contamination.
Precautions are not prov'ided to prevent or alert personnel to the hazards of breaking the integrity of the skin.
The instructions on the technique of promoting sweating to affect skin decontamination should have the following precaution added:
"If glove or bag is not removed shortly after profuse sweating starts and part washed with soap and water immediately, contamination may seep into the pores."
(IFI 50-335/80-06-10)
-15-In summary, the inspectors found the health physics procedures for the St. Iucie facility to be acceptable but recommended minor changes in existing procedures to enhance their utility.
The recommendations are contained in paragraphs 7.b. and 7.c.
The recommended bases for an ALARA program are contained in Regulatory Guides 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will be as Iow as is Reasonably Achievable (ALARA)", and 8.10, originally dated April 1974, "Operating Philosophy for Maintaining Occupational Radiation Exposures as low as is Reasonably Achievable".
In addition,
CFR 20.1.c recommends that
"... persons engaged in activities under licenses issued by NRC...
should...
make every reasonable effort to maintain radiation exposures
... as low as is reasonably achievable."
From discussions with licensee's representatives and observation of actual work practices, the inspectors found that many elements of an ALARA program did exist at the facility.'owever, licensee representatives stated that maintenance and operations procedures do not routinely receive health physics review prior to issuance.
The inspector commented that all procedures involving work on radioactivity contaminated systems, handling of radioactive material or work in radiation areas should be reviewed by the radiation protection staff as far in advance of the work as possible.
This review is necessary to insure that adequate consideration is given to health physics and engineering aspects of the work, including staffing, availability of health physics equipment and supplies, temporary shielding, engineering controls to minimize airborne radioactivity and to keep exposures ALARA.
The inspectors also found poor communications, as discussed in paragraph 4.e, between the health physics group and the maintenance group replacing the boric acid valve station.
The health physics group did not know the valve station was to be replaced until the sled mounted unit appeared at the entrance to the restricted area.
An ALARA review of the new station should have been performed, but was not.
In the professional judgement and observations of the inspectors, the AIARAprogram practiced means no one receiving radiation exposures in excess of the administration limits.
A formal ALARA program with a specialist assigned primary responsibility for ALARA and with technical'ngineering support did not exist and the inspectors recommended that one be established.
Cognizant of the efforts presently being undertaken at the cor'porate level, the inspectors found the ALARA program acceptable but urged licensee representatives to consider the recommendations in the Regula-tory Guides and implement a
formal ALQK program at the facility.
Licensee management agreed to look into the matter.
The inspectors also mentioned to licensee representatives that one of the basic elements of an ALARA program is -the capability of collecting and sorting historical radiation exposure data in order (1) to evaluate the status of any ongoing job and (2) to plan in the future for further
reductions in exposures.
The inspectors recommended that consideration be given to a real time computing system which is capable of taking care of the above.
(IFI 50-335/80-06-11)
External Ex osure Control a
~
The overall dosimetry program at the St. Lucie facility is described in their Radiation Protection Manual.
Personnel doses are maintained within 10 CFR 20.101 and "20.103 limits for both internal and external control with suitable plant administrative controls in place to provide some margin of safety for personnel exposures.
The licensee utilizes the concept of 5(N-18) for workers both permanent and temporary.
Paragraph 4.3 of the Health Physics Manual states that all permanent personnel dose records for external dose is by use of thermoluminescent dosimeters (TLD).
An airborne monitoring program is used for internal exposures and bioassay and whole-body count results are used for internal dose.
Paragraph 4.3.1 contains the details of the TLD program.
All processing is done at the general office on a monthly basis, except for potential high exposures which are to be processed immediately.
b.
Paragraph 4.3.2 of the Radiation Protection Manual covers the self-reading pocket dosimeter, which is their prime instrument for estimating daily external exposure control.
Dosimeter readings are recorded on HP Form 31 (HP-33, Revision 4) and are supplemented with estimates of neutron exposure and skin doses due to airborne contamination using either dose equivalent rate or airborne concentration measurements and exposure times.
The latter two being hand entries and transcribed from Entry Log Sheet HP-37 or HP-l.l to the computerized record file.
From discussions with licensee representatives and inspector observations, the system is not a good record system.
It is too slow, has too many hand entries and too many transcriptions from one form to another.
Procedure HP-30, Revision 7, Paragraph 8.3.3.1, states that personnel will be issued neutron sensitive TLD when entering a neutron dose rate zone; but Paragraph 8.3.3.2 states that "for daily dosimetry purposes neutron exposures shall be estimated by dose rate and stay-time calcula-tion.
The calculated dose will be added to the pocket dosimeter total."
Paragraph 8.3.3.3 states that "the calculated neutron dose should be entered on a form similar to HP-30.1 for a comparison with TLD results."
No evidence was noted that such a comparison was ever done.
In addition, it should be noted that form numbers used differ from those called for in the Procedure (HP-30, Revision 7 and HP-33, Revision 4).
Co Chapter 6 of the Health Physics Manual Chapter 6, specifies the licensee's exposure control system.
The guidelines are:
500 mrem/week whole body, etc.
(Paragraph 6.1.1.2) with exceptions.
The exceptions (Paragraph 6.1.1.3) are:
extensions to 800 mrem/week without NRC-4 form and 1000 mrem/week with it and with the approval of the Health Physics Supervisor.
With a completed NRC Form 4, over 1000 mrem/week can be given when requested by the individual's supervisor and approval by the HP supervisor and prior notification of the Plant Superintendent and/or Plant Manager.
Chapter
further states that doses for women should not exceed 500 mrem during any
-17-two consecutive months.
This, too, can be extended if she and her supervisor request it, the HP supervisor approves it and prior notifi-cation is given to the Plant Manager.
Paragraph 6.1.1.3, Subparagraph 2 further states that no individual shall be allowed to enter the Radiation Control Area (RCA) when his dosimeter (self-reading pencil)
results indicate a quarterly dose of >800 mR (2150 mR with completed NRC-4 form) until his TLD is read, reported and verified. If his TLD indicates less than 1100 mrem (2750 mrem with completed NRC-4 form) he may be allowed back in the RCA.
His dose is to be monitored closely until he reaches either 1100 mrem or 2750 mrem at which time he shall not be allowed within the RCA except for emergencies.
In any event, every effort shall be made to insure doses do not exceed either 1250 mrem or 3000 mrem.
Emergency exposures are also considered in the Health Physics Manual.
To prevent a serious injury or destruction of equipment which could result in a serious injury a whole body dose of
Rem or less is considered appropriate by the licensee except for life saving actions where a whole body dose of 100 Rem or less is considered appropriate.
Emergency exposures have never been utilized by the licensee.
In an attempt to determine how well the exposure control system works, calendar year 1979 dose records were reviewed.
Those individuals who had received
>1.9 Rem were noted. It was further noted that the bulk of the total dose was received during an outage in the second quarter of calendar year 1979.
The inspectors then attempted to determine if a correlation was made between pocket dosimeter records and TLD dose records.
Licensee representatives stated that no program was in place to routinely do such a correlation even though the Health Physics Manual states that there should be.
Licensee representatives responses were,
"The weekly lists of dosimeter results were scanned and for those that appeared reasonable nothing was done."
When questioned as to what was reasonable, no firm answer was given.
The inspectors proceeded to correlate the TID and pocket chamber data by searching the weekly dosimeter files kept in the record vault.
In completing this correlation, it was concluded that no correlation had been done and that there was a good possibility that administrative guides could have been broken and certainly the potential for exceeding dose limits exists.
Using TLD results as the base, the percent difference between TLD and pocket dosimeters varied from a low of -26), to a high of +91'j in the second quarter of calendar year 1979. It was further noted that the bulk of the second quarter exposure results occurred during the weeks of April 30, 1979, through May 14, 1979.
The failure to compare pocket dosimeter and TLD readings constitutes potential noncom-pliance with
CPR 20.201(b)
and is therefore unresolved pending further review by the licensee and the NRC to determine if the dose limits delineated in 10 CFR 20.101 could have been exceeded.
To determine if the fact that no correlations were 'made during that period was routine or if it was due to the hectic pace during an outage the inspectors proceeded to compare the TLD ms.
dosimeter results, using dosimeter results
>100 mrem, for the January 1980 period.
This encompassed a list of 32 individuals with pocket
l I
-18-dosimeter results ranging from 100 mrem to 810 mrem and TLD results from 0 to 330 mrem.
Out of the total number, 20 individuals had differences
>25/.
These ranges are similar to those found for the outage.
For the period of time that TLD and pocket dosimeter results were not compared the probability exists that exposure limits could have been exceeded.
The inspectors stated that the licensee should make the comparison for those periods missed.
In reviewing the dosimetry program the inspectors reached several conclusions summarized as follows.
(1)
The correlation between dosimeter results and TLD results should be completed and evaluated at a minimum of once a month.
(2)
The time period for pocket dosimeter accumulations should be changed to perhaps every month to allow direct correlation with the TLDs as opposed to the present weekly accumulations.
(3)
Some value for percent difference should be established which if exceeded would initiate an investigation;
+25/ is a suggested value.
(4)
Data handling and processing should be upgraded to automatically correlate dosimeters and TLD results and identify those outside the established value.
(5)
Blind faith acceptance of TLD results is not acceptable practice.
This latter conclusion is especially important after observing the way the TLD is worn.
From inspector observations the TLD is worn backwards more often than it is worn correctly and that it is shielded by the dosimeter in many instances.
These practices were observed to occur even in the HP staff.
The inspectors also observed on two successive days that the same RPM was wearing his dosimeter and TLD clipped to his belt on the side of his hip.'hat practice is contrary to Proce-dures (HP-30, Revision 7, Paragraph 8.3.6),
and sets a poor example for the rest of the plant personnel.
The inspectors suggested to licensee representatives that Paragraph 8.3.6, requiring taping of the dosimeter package to the front of the PCs and Paragraph'.3, Health Physics Manual, requiring TLDs to be worn on the front side of the upper trunk, be enforced.
Specifically, it states that the plastic bag holding the dosimeter, TLD and neutron TLD be taped to the body.
The inspectors observed that four out of four individuals suited in protective clothing had the plastic bags dangling in front of their chests - all backwards.
The inspectors informed licensee personnel that failure to follow established procedure is in noncompliance with Technical Specification 6.11 (50-335/80-06-13)
which requires that
"Procedrues for personnel radiation protection...shall be....adhered to for all operations involving personnel radiation exposure."
I I
-19-In summary, the inspectors found the external exposure control program to be acceptable, but recommended the improvements addressed in para-graph 9.f. and 9.g. carried out.
10.
Personnel Dosimeter Pro ram a.
Personnel dosimeters (pocket dosimeters
- pencils)
are described in Health Physics Procedure 32, Revision 4.
The licensee has an excellent program for the control and use of their pocket dosimeters.
Drift and source checks are made each six months and/or after damage or dropping.
Source checks are done to predetermined exposures in the dosimeter cali-bration and must fall within +16/.
Drift checks are, after zeroing, 0 to +2/ of full scale after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.<
Upon passing both tests the dosimeters are color coded for ease in determining the time for the next check.
This program is comparable to that suggested by ANSI N13.5.
b.
Pocket dosimeter control is by Health Physics Procedure 33, Revision 4.
All pocket dosimeters are maintained at the entry to the Radiation Control Area (RCA).
Upon issuance, the number is recorded and upon exit the reading of the dosimeter is recorded by name and number.
Rezeroing is required after each exit except for those dosimeters that are permanently assigned.
All are rezeroed at 400 mrem if not sooner.
Any offscale dosimeter reading requires an exposure investigation.
Dosimeter results are normally entered into the record weekly except during outages when they are recorded, as a minimum, daily.
They are the prime means of daily exposure control.
c ~
Details of the personnel TLD program are contained in Health Physics Procedure HP-30, Revision 7.
The licensee, including St. Lucie uses additional two-chip modified TLD-albedo system for neutron doses.
All beta-gamma TLDs are kept at the entry to the RCA and are issued in conjunction with a pocket dosimeter.
Upon exiting both are returned at the entry point where they are stored.
Neutron TLDs are kept by health physics personnel.
The normal period of exchange is monthly.
All TLDs are read out at the general office.
Weekly readings of accumulated pocket dosimeters and monthly TLD doses are given to the various supervisory personnel, to health physics, and are recorded in the individual records.
The TLD is normally the basis for the indivi-dual's dose record.
d.
Read-out of TLD is conducted at the general offices.
After each beta-gamma TLD is read out it is exposed to a built-in Sr-90 "calibrator" and given an exposure of 500 mrad. It is then reread and must meet a
sensitivity of +15/ of some predetermined value.
The inspectors informed licensee representatives that using the Sr-90 calibrator was no more than a sensitivity test for that particular TLD chip and not a calibration of the reader.
The inspectors estimated that the TLD reader and system have not been calibrated for beta-gamma in the previous three months and have not been calibrated for neutrons since May 1977.
In
-20-addition, the inspectors recommended changes to the TLD reader proce-dures (paragraph 7.C.12).
Licensee representatives informed the inspectors that they are trying to obtain a Cs-137 calibration source for their own use and are also negotiating with the University of Michigan for calibration services.
Controls for the TID system are kept at the plant and consist of six TLDs kept at six locations.
These six, one of which is at the entry to the RCA, are then averaged and used for background subtraction.
The inspectors recommended that this practice be discontinued and only the controls stored at the entry to the RCA be used for background corrections.
e.
In summary, the inspector found the personnel dosimetry program at St. Iucie to be acceptable, but recommended improvements outlined in paragraph 10.d. above.
ll.
Internal Dosimetr a
~
Accountability for exposure to airborne radioactivity is maintained by calculation of airborne concentrations and stay time of personnel in the area.
Air sample filters and/or activated charcoal cartridges are counted on a
Ge-Li detector and an evaluation 'made by computer to determine MPC's as well as beta skin dose.
Individuals exposed and time of exposure are determined from RMP entry logs and MPC hour calculations determined and logged.
Health Physics Operating Proce-dure HP-22, Revision 5, Air Sampling, includes formulas for manual calculation of air concentrations using the gas-flow proportional counter.
However, collection efficiencies of filters and cartridge, necessary in the calculations, were not known by the health physics technicians.
These parameters are included in the computer program.
During a portion of the appraisal period, the health physics computer failed.
One computer is used for both whole body count evaluation and air sample analysis.
The ability to adequately evaluate air sample results was severely curtailed by the excessive reliance on computer results.
The inspectors recommend the upgrading of technical background and provisions for necessary information to the health physics technicians to perform simple air sample analyses.
b.
An in-house whole body counter is used to establish baseline data for new employees, support for the air sampling program and evaluation of suspected or actual uptake of radioactive material.
A Bio-Nuclear Measurement System coupled to a Canberra multi-channel analyzer is used.
Normal'counting time is 600 seconds.
A 30,000-second background count is run monthly.
Records reviewed from September 1979 to March 1980 indicated background counts were taken usually each weekend and as a minimum monthly.
A thyroid counting device was attached to the whole body counting unit but was not functional.
Counting room personnel stated that it had been out of service for months and it was not known when it would be operational.
Discussions with licensee representatives indicated that the thyroid counter unit was 'operational but that its operation somehow adversely affected the multichannel analyzer whole
-21-body counting system so it was not used.
The inspectors recommended that this problem should be resolved and the system returned to service or other evaluation methods instituted and this system removed.
Whole body counting data is evaluated by a computer program.
The inspectors recommended that the Health Physics Department establish the capability to evaluate whole body count data manually to provide backup in event of computer loss.
C.
During review of documentation of personal contamination incidents, it was noted that whole body counts had been made on personnel with known levels of external" contamination.
This is not an acceptable health physics practice without special interpretation, as noted in ANSI N343-1978, Standard for Internal Dosimetry for Hixed Fission and Activation Products, Section 15.3.3.
d.
The inspectors found the internal dosimetry program to be acceptable but recommend certain improvements.
These improvements are contained in paragraphs ll.a and b.
In addition a
system performance audit should be instituted for the internal dose assessment program to conform to standards outlined in ANSI N343-1978, Section 15.
A System Calibration Procedure HP-31, Revision 4, Calibration and Operation of the In-Vivo Bioassay System, was in place.
However, no system perfor-mance audit system was in place to assure accuracy and precision of internal dose measurements.
12.
Res irato Protection Pro ram a
The respiratory protection program was reviewed for training content and adequacy, medical examination, respirator fitting program, personnel examination results, cleaning and decontamination methods, inspection and testing, repair, packaging and storage.
b.
The medical examination to determine fitness for the purpose of wearing respiratory protective devices was conducted by a medical assistant associated with a local physicians office.
The examination consisted of completing a one page medical history questionnaire, blood pressure check, ear, nose and throat medical check, cursory throat gland check, aural examination of lung and heart actions, lung capacity check and general observation of the physiological and psychological deportment of the patient.
The medical examiner stated that he had examined approximately 200 patients the last few weeks and had not approved
for respirator use.
The primary criteria for non-approval is lung capacity readings of less than 80$ of the norm for body size.
Of the 15 personnel not approved, 10 had lung capacity below the criteria and the other five were not approved based on subjective factors as determined by the medical examiner.
The medical examintion program is considered acceptable.
C.
The respiratory protection training encompassed approximately four hours and included the requirements of NUREG-0041.
The program utilized video tape presentations, instructor lectures, question and answer periods,
and demonstration of equipment, and methods of inspection and donning.
A 20-question written examination is required at the end of the training with a grade of 70$ necessary for passing.
The written examination for a class presented March 12, 1980, were reviewed.
Two of 79 scores were less than 70't, with the remaining ranging from 75 to 100'j.
(Note:
One individual with a score less than 70$ also failed the medical exam-ination.)
The respiratory protection training program is considered acceptable.
The mask fitting system utilized Frontier Enterprises Model FE 560A equipment and a sealed booth to perform quantitative tests of individual respirator fits.
The equipment uses a NaCl challenge atmosphere.
Each individual is instructed in donning the respirator (a Scott respirator is normally used).
The booth attendent visually checks the fit and observes a negative pressure leak test.
The individual to be tested then enters the booth and attaches the test hose to the internal booth fitting.
The test operator samples the booth atmosphere and adjusts the FE 560A to read 100$ at that concentration.
The equipment is cleared and the measurement range is reduced such that a full scale response will be equal to 1/ of the booth concentration.
A procedure for conducting the test was posted and followed.
A chart recording the test results is completed and indicate the name and SS number of the individual, machine parameters and tracing of the machine indicated concentrations for each of the phases of the test.
The chart recording is retained as a permanent record.
Approval to use respirators is based upon successful completion of training examinations, medical check and quantitative mask fit.
This approval is indicated by a hole punched in the individual's security badge.
A heart shaped hole indicates approved for use of a Scott respirator including SCBA and two spade shaped holes indicate approved for Norton Respirator use only.
Names of eight individuals were selected from the Dosimetry I.og and records checked to verify the function of the respiratory protection approval system.
Personnel were assigned to maintenance, nuclear operations, instrument and health physics.
Required documentation was verified as being current for the selected personnel except for one.
Follow up indicated that this individual was not approved to wear respiratory protection and his security badge was not punched.
The fitting and control system is considered good.
The respiratory cleaning and drying station is a sink located in a
corridor in the auxiliary building with a
standard metal cabinet nearby for air drying.
Some heat is provided by light bulbs in the cabinet.
The area in front of the sink, approximately 3'
10's roped off and papered for contamination control.
The process appears to meet the recommendations of NUREG-0041 for cleaning, disinfecting, inspection and packaging.
However, the capacity of the present facilities, particularly for respirator drying, appear to be very limited.
Discussions with licensee representatives indicated awareness
-23-of the problem and commercially available equipment was being procured on a trial basis.
Continued attention to upgrading these facilities was recommended by the inspectors.
g.
'he supply of respiratory devices appears adequate.
The normal supply is rotated through the system as needed and a backup supply of new respirators is maintained.
The total quantity is approximately 250 units.
An in-plant stock of SCBA bottles is maintained at the entrance to the RAB.
Bottles are checked routinely and refilled as necessary at a local fire department facility.
On March 12, 1980, the stock of packaged, ready-for-use respirators in the storage location was
bubble helmets and 25 Scott respirators.
Two Scott respirators were at random removed from storage, unpackaged and inspected.
Smears of internal and external surfaces of the respirators and a supplied air hose showed no significant contamination levels above background.
h.
Five additional inspections of the respirator station for quantity and quality of available respiratory protective devices were made on a
random basis during the appraisal period.
quantities available ranged from 50 bubble helmets and 48 Scott respirators to 40 bubble helmets and no available Scott respirators.
The supply check on March 18, 1980, showed no Scott respirators on the shelf, available for use.
Two HP personnel were at the respirator station inspection, surveying and packaging respirators to replenish the supply.
Adequate supplies of respirators had been cleaned and were at the station for inspection and packaging.
Inspections, surveys and smears by the inspectors indicated no findings significantly different than reported above.
The inspectors recommended that additional effort is needed to assure continued available supply.
Health Physics Procedure No. 62, Revision 2, Inspection, Maintenance and equality Assurance of Respiratory Protection Equipment, Section 8.4.2.2 states:
"Inspection and maintenance shall be performed by responsible and thoroughly trained Health Physics personnel."
and further, "Maintenance on equipment shall be performed by trained Health Physics personnel."
The criteria for determining "thoroughly trained" and "trained" could not be definitively established.
The plant health physics technicians have attended an eight-hour training class on the SCBA units presented by a factory representative and have a vendor-issued certification.
However, during the period of the appraisal, much of the respirator cleaning, surveying and inspection was being done by non-licensee Technicians.
Specific senior contract HP technicians were authorized by letter from FPM HP management to perform these functions while assigned to the plant.
These senior personnel are ANSI qualified.
One contract HP technician performing the inspection function was interviewed.
He stated that he had received no formal training in the inspection 'of respirators, but had been instructed on-the-job by a plant HP technician.
Neither the content nor fact of the instruotion was documented.
The inspectors recommended that criteria be established and training documented.
(IFI 50-335/80-06-14)
I
-24-Health Physics Procedure No. 62, Revision 2, Section 8.5 states:
"To protect respiratory protection equipment, proper storage conditions must be maintained.
The below listed requirements shall be followed for all equipment in-service, equipment removed from active use and stored until needed, and equipment requiring maintenance."
and further states,
"Respiratorsare to be stored face down on the lens to prevent distortion of the sealing surfaces.
Care is to be taken not to scratch the lens."
During this appraisal period, respirators in storage were noted to be in both lens down and lens up positions. It was noted that during the reactor outage period of the appraisal when respirator usage was high and supplemental HP personnel were authorized to perform respirator, inspection, packaging, and storage, there appeared to be no recognition of the correct respirator storage position requirement.
This condition is contrary to HP Procedure HP-62, Rev.
2 NUREG 0041 and Technical Speci-fication 6.11 and is an item of noncompliance (50-335/80-06-13)
HP Procedure No. 62, Revision 2, Inspection, Maintenance and equality Assurance of Respiratory Equipment in Section 8.4.2.2 requires completion of applicable sections of HP Form 62.
Contrary to procedures and Tech-nical Specification 6.11 HP 62 is no longer used for this purpose and is an item of noncompliance (50-335/80-06-13);
Discussions with a company representative indicated that the SCBA units are considered emergency equipment and are assigned numbers El through E45 for the units they have.
Twenty-five of these are complete SCBA units and 20 are SCBA face masks only.
Inspections are documented by a one-line entry on a
form showing equipment numbers (E XX), date, location, status of equipment, tank level and initial of inspector.
Records were available to show inspections were completed for January and February 1980.
The February inspection record showed one SCBA unit was "lost", three units had failed regulators (and were out of service)
and two were found with air tanks less than full.
Notes on the record indicated that one tank was replaced with a full tank and one was assigned to respirator training and did not require a full tank.
'
An inspection of five yellow wall-hung SCBA cases located in the Reactor Auxiliary Building (RAB) was made.
Three cases were marked as empty and were.
Two cases immediately adjacent to the RAB entry point contained SCBA units.
Face pieces were sealed in plastic bags but only one contained the required HP No.
65 inspection tag.
This is contrary to procedures HP-65 and Technical Specification 6.11 and is an item of noncompliance (50-335/80-06-13).
Tanks were full and equipment appeared in acceptable condition.
Six Scott Air Pak con-tainers located at the RAB entrance from the Hot Iocker Room were inspected.
Four contained SCBA units and two were empty.
The four SCBA units had the face piece bagged and current HP No.
65 tags inside, tanks were full and the equipment appeared in an acceptable condition.
In discussions with licensee representatives concerning the empty containers, they indicated that they had altered their philosophy as to placement of emergency SCBA units in the RAB.
Rather than locate the units at various sites throughout the RAB, units are now placed at
-25-the entrance, i.e., corridor by the HP control center and entrance from the Hot Locker Room.
They feel that at these locations the emergency units are more readily accessible in the event of need and would not require entering a potentially hazardous area to procure emergency equipment.
The logic of this location change appeared appropriate.
However, the inspectors recommended that empty con-tainers be removed from wall and entry locations to prevent the misleading assumption that units are available when in fact they may not be.
Procedure HP-62 states:
"Each SCBA unit, supplied air suit and separate manifolds, hoses, face pieces and supplied air breathing regulators are to be assigned a unique number and records maintained for that piece of equipment".
The supplied air filter and manifold units are not uniquely numbered nor are
"records maintained for that piece of equipment."
The normal respiratory protection supplied air system uses plant service air and passes it through Bullard filters to mani-folds located on the filter unit.
Labels are placed on each filter unit to indicate when the filter was chan'ged.
However, no other record of maintenance, inspection or service to the unit is maintained.
A licensee representative stated that the procedure requiring the unique numbering and documentation is in the process of being changed, but had not been completed as of this date.
Handwritten notes in the HP Procedure Manual in the HP Office indicated these requirements were to be deleted.
The entries were neither signed nor dated.
The inspector noted that failure to follow existing procedures is contrary to Technical Specification 6.11 and an item of noncompliance (50-335/80-06-13).
CFR 20.103(c)
requires, in part, that when respiratory protective equipment is used to limit the inhalation of airborne radioactive material pursuan to paragraph (b)(2) of this section, the licensee may make allowances for such use in estimating exposures of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15, "Acceptable Programs for Respiratory Protection".
Section CD 8.a of Regulatory Guide requires "Respirible air of approved quality be provided" in accordance with "Commodity Specification for Air",
G 7.1-1966, which in Section 2.3, entitled Quality Tests for Grade D air requires tests for oxygen, hydrocarbons, carbon monoxide and carbon dioxide.
Procedure HP-62 in Section 8.3 specifies that the breathing air "must meet the requirements of grade D breathing air as defined by the CGA Specification G 7.1-1966."
The instructions provided in the procedure are inadequate to provide assurance that the requirements are met.
No provisions are stipulated for sampling or testing of the breathing air supply for oxygen, condensed hydrocarbons or carbon dioxide content.
Not only is the procedure inadequate, but of more importance, no sampling or testing of the supplied air for the above potential con-taminants is actually done.
A carbon monoxide monitor is in line with the breathing air and is set to alarm at
ppm.
Discussions with licensees representatives indicate that a dedicated breathing air system has been funded and will be installed in the facility. Lack of sampling of breathing air is contrary to the requirement of
CFR 20.103(c)
and is an item of noncompliance (50-335/80-06-15).
-26-p.
During the period of the appraisal, several, instances were observed where engineering and administrative controls were used to minimize the need for respiratory protection.
The inspectors noted one instance where work was held up on the basis of air sample results and ventilation was increased to clear the area of airborne radioactivity and several instances of pre-work decontamination to reduce airborne potential.
While instances of preplanning and use of engineering controls were observed in practice, there appeared to be little or no formal ALARA program for this purpose.
HP Operating Procedures HP 66, Revision 1, Respirator Fitting and HP 67, Revision 1, Respiratory Protection Training, state that respir-ator fitting frequency and requalification training shall not exceed 24 months.
A random check of personnel records indicated this frequency was met.
A discussion was held with the HP training coordinator to determine his system for assuring the 24-month frequency was met.
He exhibited handwritten lists of plant personnel showing dates of last medical examination, respiratory protection training and respirator fitting and dates when each were again due.
He stated that he manually reviewed the past records of each individual to compile the listing and notified management and the affected individual when retesting was required.
On page I-9 of a previous NRC inspection, reported in 50-335/78-19-03, licensee commitment had been made to incorporate the traihing records into a
computer program in 1978.
This has not been done.
r.
An inspector reviewed the reported instances of personnel contamina-tions for the plant in 1979, as well as the corresponding personnel contamination worksheets.
On two instances, personnel who would not be decontaminated further were sent home with significant contamina-tion on their person.
While it appeared that good judgement had been exercised in these two cases, the inspector observed that the plant personnel decontamination procedure should contain criteria or guidance as to when a dose assessment and/or investigation is required, and when medical assistance must be summoned.
A licensee representative stated'hat the procedure would be modified to address these concerns.
(IFI 50-335/80-06-17)
s.
In summary, the inspectors found the respiratory protection program at St. Lucie to be acceptable.
Nonetheless, improvements were recommended to enhance the program and are contained in the foregoing paragraphs.
13.
Medical Emer encies On March 19, 1980, the inspectors observed the licensee's response to a
medical emergency in the reactor containment building (RCB).
A nuclear operator (NO) was working in the pressurizer cubicle in the RCB performing val've lineups while wearing a full set of protective clothing.
The NO became ill and called out for help.
When assistance arrived, the NO was unconscious and 'in shock.
He was later said to have been suffering from heat exhaustion.
The plant's first aid team arrived promptly and cared for the NO until the ambulance with emergency medical technicians aboard arrived and provided medical assistance to tPe operator.
The operator regained
"27-consciousness in the ambulance.
He was transported to the hospital, where he was kept for a short time and released.
The individual's protective clothing was removed at the step-off pad leading from the RCB and a
contamination survey performed with the RM-14/HP-210 personnel frisker while the first aid team was administering first aid:
The plant's assistant health physics supervisor accompanied the operator,to the hospital.
The response to the medical emergency by the plant staff was good.
The major factor contributing to the emergency was the high temperatures in the pressurizer cubicle (approximately 130~F).
After the emergency, the licensee established a "two-man rule" for areas such as the pressurizer cubicle and the regenerative heat exchanger room, to prevent an individual from entering these areas alone.
14.
Instrumentation a
~
The inspectors observed a variety of health physics instruments and equipment (portable survey instruments, portal monitors, personnel friskers, pocket dosimeters, air samplers)
in use, observed the calibration of instruments, check calibration stickers, performed battery checks for selected portable instruments, and selectively examined calibration records for survey instruments in use.
An inspector discussed the radiation survey instrument calibration program with an electronic technician who repairs the instruments, with the HP technicians that calibrate the instruments and with technicians who use the instruments as well as licensee management.
b.
During the review of health physics training records the inspector noted that the individual currently assigned to calibrate portable radiation survey instruments had not received any formal training in the use of the calibrator or the calibration of instruments, nor did the records indicate that the technician had demonstrated proficiency in calibrating instruments as had other technicians.
In discussions with the technician, he stated that his training consisted of reading procedures and performing calibration while another technician that had calibrated instruments observed.
The inspector stated that a
well-trained and qualified individual is necessary to ensure that instruments are properly calibrated.
This inspector stated that a
formal training and qualifications program should be established and results should be documented.
(IFI 50-335/80-06-17)
c ~
Plant Procedure HP-13B, RM-14 and RM-17 Operation Check, Paragraphs 8.13 - 8.17 describes the procedure to be followed for response checking the RM-14 and RM-17 with the HP-210 probe.
However, this procedure does not response check the instrument, but rather does little more than check the linearity of the instrument as the scales are changed.
A review of the Instrument Calibration Data Sheets (HP-11) for instruments currently in use revealed that the results of the source response check are not being entered on the data sheets as required by Paragraph 8.17 of procedure HP-13B.
This is another example of failure to follow procedures and is an item of noncompliance (50-335/80-06-13).
The source used for the quarterly response check (Ra-226) is not representative of the radionuclide compositions of the
-28-contamination encountered in the plant and therefore is not a satis-factory source to use for checking the RM-14/
HP-210 instruments.
Procedure HP-13B contains no criteria for determining when the RM-14/
HP-210 is functioning properly during the quarterly check.
The inspector stated that this procedure is inadequate and should be reviewed.
(IFI 50-335/80-06-10).
The inspector observed that portable health physics instruments were being checked prior to use by holding the instrument near a radiation source and observing that the instrument responded to radiation (instru-ment read greater than some value).
The inspector stated that this check does not insure that the instrument is functioning properly.
The response is checked on only one scale and a reading above a preset point does not necessarily mean the instrument is functioning properly.
The inspector stated that the procedure described in ANSI N323-1978, should be used for response checking instruments.
This procedure requires that the instrument be exposed to a check source immediately following calibration in a constant and reproducible manner.
Reference readings should be obtained on each scale normally used. If the instrument response to the check source on subsequent response checks differs from the reference reading by more than 20/, the instrument should be removed from service and recalibrated.
An inspector reviewed the inventory of portable health physics instru-ments and equipment.
It was noted that four days into the outage, the plant only had three out of ll teletectors in service.
A licensee representative stated that additional teletectors had been ordered, but had not been received.
An inspector reviewed the maintenance history of portable health physics instruments and discussed the maintenance of instruments with an ISC technician.
Between August 1979 and March 1980, the average length of time an instrument stayed in the ISC shop for repair was 94 days and had to be returned to IRC for further repairs or adjustments an average of two times when the instrument could not be calibrated.
The teletectors had a dispropor-tionate number of failures and difficulty in-completing a satisfactory calibration following repair.
Discussions with the ISC technician who currently performs most of the repairs on survey instruments indicated that three major problems exist with the teletector:
broken wires due to rotation of the probe, broken wires that resulted from opening the case for calibration, and unbalancing of the meter due to rough handling.
The inspector stated that significant time could be saved by the consolidation of calibration and repair of survey instruments into a single group or, at least within the same physical area.
Under the current system the IRC technician does not have a
check source to verify the satisfactory operation of the entire instrument (electronics and detector).
The inspector also noted tha the ISC technician has not received any specific training on the repair of radiation survey instruments.
The licensee should consider sending the individuals who repair instruments to vendor sponsored training course The inspectors reviewed the radiological instrumentation available in the control room.
The combined total of 53 monitors represents a
large number of monitors relative to other plants of this vintage.
The inspectors were told by licensee representatives that the liquid effluent monitor was presently being change)
because of the high background on the monitor (approximately
cpm).
The inspectors observed the partial installation of the new monitor in the basement of the auxiliary building.
Analytical capabilities of the Ge-Li systems on site were independently evaluated by the NRC and discussed in Report RII 50-335/80-01.
g ~
In summary, the inspectors found the instrumentation at the St. Lucie facility to be acceptable although improvements were recommended in the maintenance and calibration of portable instruments.
15.
Health 'Ph sics Surveillance and Access Controls a
~
The inspectors reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labelling of radioactive material during tours of the plant.
The posting and control of radio-logically controlled areas appeared to be adequate.
An inspector reviewed selected records of radiation, contamination, and airborne radioactivity surveys performed between January 1,
1980 and March 18, 1980, discussed the survey results with licensee repre-sentatives, observed technicians performing various surveys and performed independent surveys of areas.
The frequency of surveys performed appeared to be adequate.
c ~
Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained covering the activities recom-mended in Appendix A of Regulatory Guide 1.33, November 1972.
Regulatory Guide 1.33, Appendix A, Section G.5(c) states that written procedures for surveys and monitoring should be prepared.
Plant Procedure HP-41 states, in part, that if an item is to be removed as an unconditional release from the RCA, Health Physics shall ascertain that the item meets the criteria described in Plant Procedure HP-71, Paragraph 4.3.2.
Procedure HP-71, Paragraph 4.3.2 states that the release limit for uncontrolled material leaving the RCA is 100 counts per minute per probe area (beta-gamma)
using the RM-14/HP-210 instrument (approximately equivalent to 1,000 dpm/probe area)
and no detectable removable contamination.
During a tour of the clean toolroom the inspector noted an orange wrench hanging on the board.
The orange color-code is used by the licensee to designate tools that are used in the radiation control area (RCA).
Surveys of the tool performed by the inspector indicated the tool was contaminated to levels greater than 10,000 dpm per probe area.
Surveys performed by the licensee indicated the tool had fixed contamination on the handle of approximately 30,000 dpm per probe area.
The tool was removed to the contaminated toolroom in the RGB No other contaminated tools were found in the toolroom.
A licensee representative stated that the clean toolroom was surveyed on
-30-a monthly basis and the contaminated tool was not noticed in the.
previous survey.
The inspector stated that the orange paint should have been removed when the tool was removed from the RCA. If the orange color is routinely removed when the tool is removed from the RCA, the clean toolroom attendent would have reason to suspect that any orange tool is contaminated and promptly notify Health Physics.
The inspector stated that the presence of a tool contaminated above the limits allowed by Plant Procedure HP-71 for uncontrolled release was in noncompliance (50-335/80-06-18)
with Technical Specification 6.8.1.
During tour of the auxiliary building an inspector noted a sign at the entrance ot the hot machine shop stating the area was a "contaminated area - on the table".
Independent surveys performed by the inspector revealed that a drill press located in the room was contaminated with loose surface contamination of approximately 70,000 dpm.
The drill press was not posted as a contaminated area.
A review of previous routine surveys in the room indicated that only the walkways were surveyed; no smear surveys were taken on the machines.
A licensee representative confirmed the fact that the routine survey only included the walkways.
The inspector stated that the machines, tables and cabinets, as well as the walkways, should be included in the routine surveys performed in the hot machine shop.
The station has no radiation survey instruments with ranges greater than 1,000 R/hr.
The inspector stated that the station should consider acquiring instruments with ranges up to 10,000 R/hr to be used in the event of an accident.
Instruments with ranges greater than 1,000 R/hr were needed immediately following the accident at Three Mile Island, but were not available.
The inspectors reviewed the licensee's methods for controlling work in radiologically controlled areas.
During tours of the plant the inspectors discussed the methods for controlling work with health physics personnel (plant staff and contract technicians)
and other members of the plant staff.
Most individuals questioned had an adequate knowledge of the protective clothing requirements, radiological conditions, work to be performed and specific radiation work permit requirements.
However, one contract health physics technician assigned to cover work on two pressurizer spray valves did not know what the workers were assigned to do, contamination levels or airborne radioactivity levels in the work area, although the men were working in air-fed hoods.
A licensee representative stated that the contract technician would be instructed that they must know the radiological conditions and the work being performed if they are assigned to provide health physics coverage for a specific job.
Plant Procedure HP-l, Paragraph 8.1.4 states that personnel working under RWP conditions are responsible for following RWP directives.
Standing RWP 80-01 and 80-04 issued January 1,
1980, both specified that the RWP does not cover airborne areas.
On March ll, 1980, an inspector noted that a
number of entries had been made into the area
of the gas decay tanks and waste gas compressors using SRWP 80-01 and 80-04.
This area is posted as an airborne radioactivity area.
When this was brought to the attention of a licensee representative, he acknowledged that entries should not have been in the airborne radio-activity area using the reactor auxiliary building general entry RWPs.
A specific RWP was prepared'or entry into the area.
The inspector stated that failure of these individuals entering the area of the waste gas compressors and gas decay tanks to follow the directives on the RWP was another example of noncompliance (50-335/80-06-18) with Technical Specification 6.8.1.
h.
The frequency and location of air sampling appeared gener'ally acceptable.
Some 450 air samples had been taken from January 1,
1980, to March 20, 1980, with 68 of these taken in the first three days of the refueling outage.
The sampling locations were throughout the RAB and RCB with increased frequency in the RCB after plant shutdown.
Exceptions noted were:
(i)
No air samples for the evaluation of tritium were recorded on the HP air sample log until March 18, 1980, after the question had been raised by the inspectors.
Tritium sample evaluation may be appropriate for the fuel pool area and the reactor containment building for personnel entry.
(ii) Plant personnel were observed entering one area of the pressurizer cubicle and no air sample results could be produced to show the basis for respiratory protection requirements.
(IFI 50-335/
80-06-19)
Entries into the reactor containment building covering the period January 1,
1980 to March 11, 1980, were reviewed.
The radiation work procedures used were:
SRWP 80-2 covering all personnel SRWP 80-3 covering operations and general entry, and RWP 80-105 issued to cover RCB and RAB, all elevations for the refueling outage.
Individual personnel were logged on Entry I,og Sheet HP No.
37 which lists TID No.,
name, date, RWP No., time in, time out, neutron dose and skin dose.
Beta skin dose is calculated from air samples taken from the RCB and evaluated by computer program (Form HP No. 67).
Forty-four entries were made in the period reviewed.
HP No.
37 forms were completed for each entry including dose data.
A crosscheck of air samples taken indicated that RCB air samples were taken and evalu-ated within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of each entry, the beta skin dose evaluation
.computer program ran and dose information entered on the HP No.
form calculated by dose rate times stay time.
Operations Procedure HP 1, Revision 9, Radiation Work Permit, specifies HP 1.1 form to be used for listing personnel authorized to work under the RWP.
The form more frequently used in the above instances was HP No.
37 which is I
similar.
This is another example of noncompliance for failure to follow procedures (50-335/80-06-13).
Document HP 33, Dosimeter Exposure Iog, located in the HP Office is a listing of all plant personnel and provides spaces for neutron and beta skin dose exposure data.
As of March ll, 1980, data has not been entered by all health physics personnel in this listing for all entries.
The HP 37 forms are collected and sent to dosimeter administration monthly for inclusion in the individual accumulated dose records.
Neutron doses and beta skin doses are not routinely included in the dosimeter exposure log (HP No. 33) for day-to-day exposure control.
Corrective action was implemented imme-diately after discussion with plant personnel.
During tours of the plant, an inspector checked the alarm set point of the RM-14/HP-210 personnel friskers at the control point for the containment building and the auxiliary building.
In each case the instrument was set to alarm only if the count rate reached full scale (500 cpm on the lowest scale).
A licensee representative stated that the alarm was not used and that the worker was instructed to notify health physics if any increase in count rate was detected during frisking.
However, plant personnel questioned by inspectors indicated they would consider the contamination levels satisfactory if the alarm did not sound.
The licensee representative further stated that the instruments were not set to alarm if the plant's release limit of 1,000 dpm per probe area because it would result in numerous spurious alarms.
The inspector stated that consideration should be given to providing shielded frisking booth or relocation of the friskers if high background is the cause of the spurious alarms.
The inspector stated that the instruments should be set to alarm if the plant limit of 1,000 dpm is exceeded.
Signs should be placed near each RM-14/HP-210 frisker stating how much of the body should be frisked, how long it should take to get a satisfactory evaluation, that the alarm set point should not be changed except by qualified health physics personnel and to notify health physics if the frisker alarms.
Plant Procedure HP-13B, RM-14 and RM-17 Operation Check, requires that the RM-14 and RM-17 friskers be response checked at least quarterly.
The technical inadequacies of the plant's method of checking the instruments are discussed in Paragraph 9.c. of this report.
The inspector stated that since the portal monitors will only detect gross amounts of radioactivity, the personnel friskers are the only instruments that will ensure that plant personnel do not leave the plant contaminated above the plant limits of 1,000 dpm.
The response of the friskers should be checked with a check source representative of the predominant radionuclides present in the plant utilizing the procedure specified in ANSI N323-1978, Radiation Protection Instrumentation Test and Calibration, and the proper functioning and alarm set point verified prior to the first use and at least daily when in continuous use.
An inspector 'discussed. with licensee representatives an evaluation of beta radiation doses received by personnel working in the primary side of the steam generators.
A licensee representative stated that beta radiation doses received by workers entering the primary side of the steam generators had been insignificant.
He also provided the inspector
i
-33-with a preliminary copy of the study which the plant had conducted to provide support for this conclusion.
After reviewing the report, the inspector stated that the data provided failed to adequately support the conclusions reached in the report.
The licensee representative stated that the report would be reviewed and additional data collected, if necessary, to adequately determine if beta radiation was a signifi-cant problem in steam generation work at the plant.
The inspector stated that this item would remain open (IFI 335/80-06-05)
pending review of the final report during a subsequent inspection.
An inspector checked each detector on all of the plant portal monitors by placing a 0.36 pCi Co-60 source in contact with the frame surface at each detector.
In all cases the monitor failed to alarm.
When checked similarly with an 8.0 pCi Cs-137 source the monitor alarmed in most instances but not all.
The inspector stated that the portal monitors did not appear to be set to sufficient sensitivity to detect contamination on persons or objects passing through the monitors that were contaminated at or slightly above the release limit of 1,000 dpm.
The licensee representative stated that the present portal monitors could not be set low enough without giving numerous spurious alarms due to changes in background radiation levels, but that replacement of the current monitors was presently under consideration.
The inspector stated that the counting time and alarm set points of each portal monitor should be set to detect contamination on individuals that is above plant limits for the unauthorized removal of radiaoactive material from the plant.
The HP Daily Area Surveillance Survey requires contamination surveys of 44 specific areas and radiation level measurements of 35 areas.
A weekly radiation and contamination survey schedule requires radiation and contamination surveys of 43 rooms or areas in the reactor auxiliary building (RAB), fuel pool areas, toolroom, control room, counting rooms, etc.
In addition, a monthly schedule provides for surveys of outside areas around the RAB, the perimeter of the radiation control area, administration or office areas and secondary site surveys.
One hundred area specific survey forms with drawings of area and equipment are used.
Current completed surveys are maintained in a log in the HP Office (RAB).
A status board showing the RAB and RCB is located in the entrance ot the RAB immediately outside the HP Office.
Radiation and contamination levels are identified on an erasable overlay.
Dates of survey data are normally indicated.
Records of daily and weekly surveys were reviewed for the first two months of the year.
Records were in place and complete for each day and week for the period except'or weekends and holidays.
Selected routine surveys were reviewed for the same period and were also in place and completed surveys for some locations were marked as no survey done, to be surveyed by HP before any entry.
Complete routine daily survey packages for March 10, 1980, and March 11, 1980, were reviewed.
Surveys appeared complete and appropriate and status board was updated to reflect survey results.
Each survey sheet and check-off sheet has a location for signature of reviewer and date of revj.e Each survey and check-off sheet inspected had been signed by either the HP shift supervisor or HP outage coordinator.
A review of leak testing and inventory of radioactive sealed sources was made.
Records indicated that sources whose activity required a leak test by Technical Specification 3/4.7.9 had been leak tested and inventoried on the frequency required.
A radiation and contamination survey was made of the letdown heat exchanges in the RAB.
Radiation measurements were made by the inspec-tors and correlated within +20/ of the radiation levels indicated on the licensee conducted survey.
Smears of five locations in the area of the letdown heat exchanges were counted for alpha and beta gamma using licensee's counting equipment.
Results indicated no detectable alpha activity and less than
cpm beta-gamma above a background count of 33 cpm.
Smears were taken on a
tube bundle removed from reheater-moisture separator lA, secondary loop side and counted on both an NRC and an FPSL instrument.
Results indicated activity less than
cpm above background.
Two outside radioactive materials storage areas were observed in the RAB backyard.
The areas were roped and posted as "Radiation Materials Area".
Plastic wrapping covering the equipment was deterioted and tom, exposing what was assumed to be contaminated surfaces to the elements.
While no radioactive contamination was detected outside of the roped area, the potential for contamination spread by wind or rain exists.
Attention should be given to instituting appropriate controls for maintenance of outside storage areas.
Contamination and radiation surveys were made of laundered protective clothing (PCs)
ready for issue.
Single coverall type PCs surveyed showed up to 4.2 mR/hr (20,000 c/m) maximum on spots (knees, elbows, collars)
and up to 2,000 cpm general over the garments.
Smears of the garments indicated less than 100 cpm removable contamination.
Barrels of clean PCs indicated radiation levels up to 6.5 mR/hr, measured on the top of the top layer of clothing.
All measurements were made with either a Xetex or MS-3 with an HP 210 probe.
No contamination or radiation levels were detected which exceeded the specifications of Health Physics Operating Procedure HP 50, Revision 1.
Radiation Work Permits (RWPs)
are requested by personnel desiring to do specific work.
The work location and scope is completed and the RWP sent to HP for number assignment, logging, specification of radia-tion protection requirements and approval.
The person requesting the permit is assigned responsibility for securing the appropriate signatures.
Selected RWPs were reviewed for appropriateness of radiation protection requirements based upon work scope, location and conditions.
Generally, the radiation protection requirements specified appeared appropriate.
Numerous instances were noted where the instruction "as determined by HP" or "as required by HP" were entered on the Radiological Conditions section and by asterisked items in the clothing requirements section.
The authorization of RWPs by the nuclear plant supervisor when HP
-35-personnel are absent from the site may provide a significant deviation from adequate Health Physics control.
During normal operating periods health physics personnel do not work weekends or holidays.
Thus, for approximately 30% of normal opexating periods, health physics personnel approval and control of activities may be bypassed until after the fact.
Activities in the HP control center (RAB Office) were observed inter-mittently throughout the appraisal period.
The initial 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of a shift and the last 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of a shift appeared to be extremely demanding of the attention of the plant personnel.
Paging calls for HP personnel were counted at 7 per minute during some of these periods in addition to telephone calls, questions by temporary personnel, requests by maintenance and operations personnel and providing direction to the temporary personnel.
The ability of personnel to give adequate consid-eration and planning to radiation protection functions under these conditions is questionable.
Observation of self survey of personnel leaving contaminated areas and/or the RCA showed practices to be inadequate.
Hands, feet and head were normally surveyed but remainder of body was never observed to be adequately surveyed.
At this facility, TLD badges and self-reading pencil dosimeters are issued to personnel entering the radiation control area (RCA)
by Security personnel located at the entry-exit point.
Two portal monitors are also located at this location.
Discussions were held with Security personnel to determine what they felt their radiation protection responsibilities were.
Three personnel were interviewed.
Their responsibility consisted of issuing and receiving dosimeters, recording pencil dosimeter readings as stated to them by exiting personnel, and accepting blue release tags from material released by HP from the RCA.
When asked what required a blue tag for release, they indicated that everything except personal items, notebooks, etc.
It was observed, however, that numerous tools, pliars, tapes, screw-drivers, etc'
, left the RCA in the back pockets of personnel without a blue tag or challenge from Security personnel.
The tools were probably not observed by the Security personnel and may have been in the same'ockets prior to personnel entry into the RCA.
The system does not provide "...positive control of materials and equipment entering and leaving the radiation control area" as stated in Procedure HP 41, Revision 8.
Observation of personnel using the portal monitors upon exiting the RCA showed that 25 to 50'/ of the people did not position themselves in the portal monitor such that the body was parallel with the frame, the position designed for, but as much as 904 from the correct position.
The designation and posting of areas for the control of radiation and contamination appeared adequate.
One instance was noted where radiation levels at the rope boundary of a radiation area exceeded the procedure limit of 5 mrem/hr.
However, the posting requirements of 10 CFR 20 were met.
In the RAB east end corridor, 19.50 ft. elevation, a radiation
-36-level of 23 mR/hr (measured with an NRC instrument)
was measured at the rope boundary from a barrel stored inside the area.
HP personnel were notified and the condition was immediately corrected.
V.
An inspector reviewed key control for locked high radiation areas.
All such keys are maintained by Security personnel at the personnel access portal, and are issued and logged on an as-needed basis.
Operations personnel are not issued keys on a long-term basis for routine use.
Normally only health physics personnel may be issued keys to high radiation area doors.
The inspector reviewed the key log for the previous six-month period and observed that this system appears to ensure adequate key control, and that no keys appear to have been lost during this period.
w.
In summary, the inspectors found the health physics surveillance and access controls to be adequate.
Recommendations for improvements were made to licensee representatives as outlined above.
16.
Radwaste Control a.
An inspector reviewed the liquid and gaseous waste release permits for
.the third quarter of 1979, and discussed the permits with a licensee representative.
During the. review of gaseous release permits, the inspector observed that there appeared to be no correlation between waste gas tank noble gas activity concentration and the recorded expected count rates on the alert, or high alarm set points on the waste gas monitor.
A licensee representative could not provide a
satisfactory explanation for the lack of correlation.
It was not apparent that the set points of the waste gas monitor were such that automatic closure of the waste gas discharge valve would be initiated prior to exceeding the limits specified in Environmental Technical Specification 2.4.3.a.
Confirmation of this problem would constitute noncompliance with ETS 2.4.3.d.
This item will remain unresolved (50-335/80-06-20) pending further discussions with the licensee.
b.
The licensee has placed considerable emphasis on reducing the amount of solid radwastes generated at the facility due to restrictions being placed on the Barnwell Waste Burial Facility.
The established program for reducing solid waste volume is contained in the following guidelines
.
issued by the facility:
(1)
Items such as boxes, bags, and packing materials that do not have to go into the RCA should be left on the secondary side.
(2) If an item that must be disposed of as trash is throught to be uncontaminated, the item is placed in the white drums 'labeled
"CLEAN WASTE - NonRadioactive."
The waste collected in these drums is surveyed by health physics and released to the secondary side ifit is found to be uncontaminate Tools and equipment not specifically designated for RCA use are checked for contamination.
If they are found to be uncontaminated then a blue tag will allow them to be released to the secondary side.
Rad-waste containers in the RCA are for the disposal of trash.
Contaminated clothing containers are for discarding protective clothing that have been worn.
Many times clothing has been placed in trash containers and contaminated to levels that cannot be reduced by laundering.
Contaminated water should be diverted to drains. If a job requires collecting contaminated water, the water can be collected in a
pail.
The water can then be poured down a building drain.
For quite some time an accepted practice has been'to place absor-bent pads in bags containing contaminated water.
This works well to absorb the water, but when the pads are compacted in a drum the water is forced out of the pads and into the drum leaving free standing water in the bottom of the drum.
The drum compaction operation is such that this free standing water may well go undetected.
To preclude this from happening absorbent pads are not to be used for removing contaminated water unless specifically authorized by health physics.
These pads may still be used for and are recommended for controlling and limiting spills.
Oil is a unique problem because it cannot be buried, and it is not allowed to reach the liquid radioactive waste treatment system.
The only acceptable way of handling oil is not to allow it to become contaminated.
Non-compactable waste, normally metal and wood, cannot be allowed in drums that are to be compacted.
Compaction of metal or wood can tear holes in drums which requires that the waste be removed from the drum and compacted again in a new drum.
Non-compactable material is to be placed in the area designated for non-compactable waste in the drumming room unless another area is specifically authorized by health physics.
Prior to shipping a container of radioactive waste, the container must be verified to be free of standing water and oil.
This verification made by two individuals, one of which is a repre-sentative of health physics.
The other individual is the person placing the material in the container.
Containers of radioactive waste are not be left open exposed to the weather.
If the container cannot be completely filled and closed, it is closed in such a manner that rain does not enter the containe When containers are filled and closed they are taken to a location designated by health physics for processing into the waste disposal stream.
The containers are surveyed for radiation and contamination, weighed, assigned a shipping number, and inspected by gC.
Following this the container is loaded on a truck for transportation.
(12)
Containment of Radioactive Materials Prior to Packaging for Shipment.
As radioactive materials and waste are generated from work in p'rogress, the waste is placed in yellow plastic bags.
The yellow bags indicate that. the materials contained inside're most likely contaminated.
In addition to the short-term solution of minimizing waste generation through individual awareness, licensee representatives stated that longer term solutions are being sought.
The long-term solutions under consideration are incineration, on-site storage, and a combination of on-site storage and incineration.
c.
From discussions with licensee representatives the inspectors found that storage requirements for liquid and gas have not presented a
problem for normal operations and appear adequate.
For solid wastes the station presently generates approximately
barrels of compressible waste per month.
Most full barrels are presently stored outdoors in the RCA on a concrete pad or in a truck ready for shipment.
At the time of the inspection there were approxi-mately 100 drums of waste being stored on site awaiting shipment.
The restrictions on the quantity of waste being accepted at the Barnwell site are beginning to show an effect on this facility, but the'problem is by no means crucial as yet.
The inspectors found the solid waste storage,and control onsite to be acceptable.
17.
Facilities and E ui ment The licensee maintains separate analytical laboratories for chemistry and health physics.
These facilities were reviewed in detail in Region II Report 50-335/80-01.
Licensee medical treatment facilities and emergency supplies are reviewed in Region II ISE Report 50-335/79-23.
An inspector examined the Unit
change room and observed its use during high traffic periods.
The facility appears to be adequate at present, both in size and equipment. It is adjacent to the personnel decontamination area and near the control point for the Unit 1 personnel access hatch.
The inspector observed that the frisker station in the change room was occassionally subject to high background radiation levels.
This item is addressed in detail elsewhere in this report.
Plant decontamination facilities were examined and an inspector verified that dedicated areas or rooms were available and used for both personnel and equipment decontamination.
Personnel decontamination -facilities are
"39-reviewed in detail in Region II Report 50-335/79-23.
The equipment decon-tamination facility consisted of a large room located near the Unit 1 access hatch.
The room was lockable and had a separate ventilation system.
It appeared adequate for tool and equipment decontamination.
Decontamination facilities for respiratory protective equipment appeared to be inadequate, and are addressed in detail elsewhere in this report.
An inspector examined the reactor coolant and containment air sampling areas.
These areas are presently deficient with respect to NUREG-0578 (Item 2.1.8.a) criteria, but a licensee representative stated that appro-priate modifications were under evaluation to upgrade these areas consistent with NUREG-0578.
R~e-eetr The inspectors observed and discussed with licensee representatives those aids, i.e.,
models or photos, presently available to them which could expe-dite the recovery of the facility should a major protion of the buildings on site become uninhabitable.
Scale models of buildings and/or systems are not available for the facility.
Although some photography has been done on systems requiring modification, a systematic room-by-room, valve-by-valve, photographic review of the facility has never been attempted nor is such a
study planned in the near future.
The inspectors noted that the majority of valves and pipes within the facility were marked with plastic tags which not only gave the valve number but also some discription of its function.
Numerous extended handwheels were noted throughout the facility.
In those cases where large (12" or larger)
were attached to small valves (2" or under),
caution signs were clearly visible near the handwheel warning of the small valve on the other end.
The inspectors did find two handwheels just beyond the entry to the boronometer room which were attached to valves in the let down heat exchanger room that did not have any clear markings on the handwheels as to their function.
The inspectors asked for copies of the available system's PSIDs and general arrangement drawings for the reactor, auxiliary and turbine buildings.
The prints received were not controlled documents but for information purposes only.
The prints were FSAR type prints, Revision 55 dated February 9, 1976.
The inspectors also noted other groups in the plant using the same PSIDs.
Modifications to various systems have been made since, February 9, 1976.
Up to date prints should be available for general employee use.
In the event of an emergency, corporate supplies expanded technical support for the facility. Additional support is available from other FPSL facilities as well as other facilities in the southeast.
Emergency supplies are available on site and stored by the meterological towe It, is the general conclusion of the inspectors that improvements in the area of the availability of current information on systems layout and piping could be made at this facility.
Such information would not only be useful for a reentry operation should the need arise, but would also be useful for an expanded ALARA program.
19.
In-Plant S stems The inspectors toured numerous cubicles within the reactor and auxiliary building and did not notice any evidence of long-term, uncorrected liquid leaks.
The inspectors did observe some minor leaks at the boric acid valve stations located on the 0.50 ft. elevation of the auxiliary building.. The, inspectors also noted that two new boric acid valve stations were being installed.
The modular units had been fabricated outside the RCA and brought into the RCA with heat tracing and insulation completely installed.
The inspectors commented that the corrective action being taken to stop relatively minor leaks was laudable.
The inspectors also reviewed the maintenance history of the waste gas compressors.
Typically, the waste gas compressors at other facilities require a great deal of maintenance.
The inspectors found that the entire waste gas system at this facility only had eleven maintenance requests for the period January 1,
1979, thru March 15, 1980.
In addition, licensee representatives stated that the waste gas system had been already leaked checked.
In conclusion, the inspectors had no problem with the maintenance and preventative maintenance program at the facility from a health physics point of vie I
PERNANENT STAFF (}UALIFICATIONS TABLE 1 TITLE Lal
~ V Qx o.>
cC o ~
LtJ UJ c~
W CI
~ UJ Qo ~
~U s-e ~
lA cZ K D W C7 lA CB CL CL COMMENTS Health Physics Supvr.
4.0 B.S 17.5 X
ll Yrs.
4 Mos. Professional Experience Ass't.
H. P. Supvr.
2.5 9.7 X
4 Yrs.
7 mos. Professional Experience Senior Plant Technician Senior Plant Technician
-
4.0 A.S B.S 6.0 5.0 X
H. P. Admin Coord.
Radwaste/Projects Senior Plant Technician Senior Plant Technician 2.0 2.0 A.S A.S 5.8 2.5 X
Training H. P.
OPS Coord.
Assoc. Plant Technician N/A N/A N/A N/A N/A Dosimetry records and Computer OPS Non-Technical
PERMANENT STAFF QUALIFICATIONS TABLE 1 - (Continueg)
TITLE Radiation Protection Man Radiation Protection Man cC CD UK M M the%
>- II 2.0 2.0 t/)
LU UJ CD UJ CD A.S.
A.S.
+
UJ UU CL cZXD X O4C cnz:cc CY MLS
+UCL UJ UJ&
o-I-4 W O
~ UJ CO M w U Vl~
KD ca 4.8 X
5 0
-
X lA CD O
CL COMMENTS Radiation Protection Man Radiation Protection Man Radiation Protection Man 1.5 2.0 2.0 A.S.
A.S.
2.0 2.5 2.0 X
Co-Op N/A N/A N/A.
N/A N/A Coop Student Clerical Non-Technical
(}UALIFICATIONS OF SENIOR TECHNICIANS ON THE TEMPORARY H. P.
STAFF TABLE 2 TITLE UJ CD I
M Ch UJ Ch K UJ OC w CY Q cC CD
I O
UJ
+ DV cC M X O UJ M M Ch K CY CC MUJ QDO UJ UJ X 0- I-UJ UJ
+
CL cL X V Ch K CY M UJ UJ o-I-CO COMMENTS Continued Senior Health Physicist 2.0 A.S.
~ 2 4,200 Senior Health Physicist 1.0 Senior Health Physicist 2.0 A.S.
Senior Health Physicist 2.0 ASS.
Senior Health Physicist 2.0 ASS.
2.1 7,556 1.2 4,089 4.6 12,788 13.4 38,037 Senior Health Senior Health Physicist 0.1 Physicist 2.0 1.7 5,660 g
qualified by 2000 Hr-40 Week Criteria 2.0 7,269 Health Physicist
+
Health Physicist 2.0 A.S.
4.0 N/A 3.0 N/A
+ Personnel On Loan From Another Utility 2000 Hr-40 Week Criteria:
No more than 2000 working hours may be counted toward ANSI 18.1 experience requirements in any 40 calendar week period (allows limited credit for overtime).
QUALIFICATIONS OF SENIOR TECHNICIANS ON THE TEMPORARY H. P.
STAFF TABLE 2 TITLE UJ CO I K UJ NK UJ CY M CY UJ 5 UJ 0- I-LIJ
+ AO cL cr M X O UJ M M Ch K CY CY X UJ cC OCL UJ UJ 0K:
0- I-UJ
+
CL cL XO C/l M CL X DO D UJ Ml cC CY COMMENTS Senior Health Senior Health Physicist':
2.0 A.S.
Physicist 2.0 A.S Senior Health Physicist 2.0 A.S Senior Health Physicist 2.0 A.S Senior Health Physicist 2 '
A.S.
Senior Health Physicist 0.8 3,213 0.9 4,067 1.3 4,067 1.2 4,612 1.1 4,066 7.3 17)600 Senior Health Physicist 1.5 1.6 4,937 g
Qualified by 2000 Hr-40 Week Criteria Senior Health Physicist 4.0 B.A.
1.7 5,937 J
Qualified by 2000 Hr-40 Week Criteria Senior Health Physicist 4.0 A.S./B.S.
16.8 35,226 Senior Health Physicist 2.0 A.S.
Senior Health Physicist 2.3 Senior Health Physicist 1.5 Senior Health Physicist 4.0 B.S.
1.6 5,600 g
Qualified by 2000 Hr-40 Week Criteria 8.6 30,314 5.2 10,656 2.0 6,999 Contractor Personnel 2000 Hr-40 Week Criteria:
No more than 2000 working hours may be counted toward ANSI 18.1 experience requirements in any 40 calendar week period (allows limited credit for overtime).
'IGVRE 1.
ST. IUCIE PLANT ORGANIZATION Plant Manager Tech.
Supv.
Admin.
Supv.
Outage Coord.
OPS Supt.
Chem.
Supv.
RX Engr Supv.
Train Supv.
Maint.
Supv.
Startup Su t.
f32 Const.
Su FIGURE 2.
ST. IUCIE HEALTH PHYSICS ORGANIZATION (1)
Health Physics Supervisor Department Head I
(1)
Assistant Health Physics Supervisor (1)
Health Physics Administration Coordinator (1)
Health Physics Operations Coordinator (1)
Training Special Pro ects (1)
Radioactive Waste (1)
Records (1)
Dosimetry (4)
Day Shift RPM's
FIGURE 3.
CORPORATE ORGANIZATION FOR FACILITY MANAGEMENT AND TECHNICAL SUPPORT EXECUTIVE VICE PRESIDENT VP Nuclear 6 Engineering Support Group Vice President Company Nuclear Review Board Vice President Power Operations Manager of Power Resources Manager of Power Resources
, Services Plant Mana er See Figure
Power Resources Supervisor Nuclear Corporate HP Plant HP Su ervisors See Figure
fy c,
~ ~1