IR 05000344/1983008
| ML20023C712 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/07/1983 |
| From: | Book H, Cillis M, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20023C705 | List: |
| References | |
| 50-344-83-08, 50-344-83-8, NUDOCS 8305170567 | |
| Download: ML20023C712 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 5G-344/83-08
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Docket No. 50-344 License No. NPF-1 Safeguards Group Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204
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Facility Name:
Trojan Inspection at:
Rainier, Oregon Inspection conducted: March 22-25, 1983 Inspectors:
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M. Cillis, Radiation Specialist Date Signed
Approved by: 6 NAR
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F. A. W wski, Chief,GRactor Da'tef Signed Radiatio Protection Section Approved by:
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l. E. Book, Chief, Radiological Safety fa(e Signed Branch
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i Summary:
Inspection on March 22-25, 1983 (Report No. 50-344/83-08)
Areas Inspected: Routine unannounced inspection by a regionally based
inspector of the radiation protection program, including procedures, surveys,
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general employee training, posting and labeling, external and internal exposure control, organization, records and reports, ALARA and a tour of the licensee's facility. The inspection involved 25 inspector hours on site by one inspector.
Results: Of the areas inspected, no items of noncompliance or deviations were i
identified.
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DETAILS 1.
Persons Contacted a.
Portland General Electric (PGE) Company C. A. Olmstead, Manager Operations and Maintenance
- R. P. Schmitt, Manager Technical Services R. E. Susee, Training Supervisor
- D.
Keuter, Operations Supervisor
- T.
O. Meek, Radiation Protection Supervisor
- M.
Huey, Unit Supervisor Radiation Protection
- N.
C. Dyer, Supervising Health Physicist
- S.
Newcomb, Radiation Protection Engineer
- P. A. Morton, Q. A. Supervisor
- J.
Pickett, Training Specialist M. Anderson, Radiation Protection Engineer T. L. Moore, Sr. Radiation Protection Technician G. Craven, Radiation Protection Engineer b.
Non-PGE Personnel Combustion Engineering (CE)
J. McGraw, Sr. Radiation Protection Technician, Supervisor M. Latham, Sr. Radiation Protection Technician J. Christofferson, Sr. Radiation Protection Technician L. Lauham, Sr. Radiation Protection Technician Allen Nuclear Associates (ANA)
W. Allen, President ANA, Health Physicist B. Curtis, Project Manager of Engineering
- Denotes those individuals attending the exit interview on March 25, 1983.
In addition to the individuals noted above, the inspector met with and interviewed other members of the licensee's and contractors staff.
2.
Radiation Protection a.
Organization Staffing and Qualification An examination of the licensee's radiation protection organization was conducted. The licensee's permanent radiation protection organization is essentially unchanged from that described in Region V Inspection Report 50-344/80-16 and 50-344/82-15. The most significant change noted is identified in Section 6(a) of Inspection
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Report 50-344/83-01.
Inspection report 50-344/83-01 identified that the licensee's chemistry and radiatica protection organization had split into two separate groups (e.g. chemistry technicians and radiation protection technicians). A total of 12 fully qualified senior radiation protection technicians (RPTS) are currently on the licensee's permanent staff. An additional 10 chemistry technicians that are currently either fully or partially qualified as radiation protection technicians are also available to supplement the licensee's permanent radiation protection technician staff during an outage. The normal radiation protection organization staff consists of:
the Radiation Protection Supervisor, Assistant Radiation Protection Supervisor, Unit Supervisor of Radioactive Material Control (USMRC), four radiation protection engineers, 12 RPTS and nine utility workers who are assigned to the USMRC.
The permanent radiation protection staff was recently augmented to support an extended refueling outage that commenced on March 1, 1983. In support of the outage the licensee has contracted the services of 30 RPTS from Combustion Engineering (CE), 16 utility workers and 5 clerks.
The contract RPTS are composed of one supervisor, 22 senior RPTS and 7 junior RPTS.
In addition the licensee has activated four of the plants chemistry technicians to the position of senior and junior RPTS.
The inspector reviewed the resumes of the contract RPTS and verified that the assignment of the four chemistry technicians was commensurate with Section 4.5.2 of ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel". The contract RPTS and Chemistry Technicians appeared to be qualified in accordance with ANSI N18.1-1971. The review of resumes further disclosed that approximately 60% of RPTS selected had worked for the licensee during the 1982 refueling outage. The inspector also interviewed a portion of the CE-RPTS.
The examination and interviews disclosed that the contract RPTS are given plant specific training seminars and then an examination is administered by the licensee to ascertain the individuals knowledge level.
The CE-RPT supervisor also administers a generic health physics examination to all CE-RPTS. A review of the examination results revealed that the newer RPTS selected either partially or totally failed to correctly answer questions related to the calculation of air sample concentrations and the determination of Maximum Permissible Concentrations (MPCs). The involved technicians were retested and subsequently passed the examination.
At the exit interview, the inspector emphasized the need for enhancing the training seminar.
The inspection disclosed that three of the licensee's permanent staff of RPTS were temporarily promoted to act as lead radiation protection coordinators during the outage. The remaining permanently assigned RPTS have been very carefully assigned for the purpose of overseeing the contract RPT performances.
No items of noncompliance or deviations were identified.
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b.
ALARA Reviews, Planning and Scheduling The inspection disclosed that the licensee's ALARA engineer has coordinated closely with the planning / scheduling and corporate staff and has participated in daily planning meetings for the purpose of implementing the licensee's ALARA program during the outage.
The inspection disclosed that ALARA reviews and man-rem estimates for all general services and planned / scheduled work for the outage have been conducted in accordance with the licensee's Radiation Protection Manual RPM. Historical data obtained from previous ALARA reviews were used to the utmost extent possible for planning and scheduling of work associated with this outage. The degree of the ALARA review that is conducted is based on the projected man-rem I
estimates. A detailed in-depth review is conducted for all tasks for
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which exposure estimates will exceed 2.0 man-rem.
The man-rem estimates and percentage of job completion is tracked during the performance of the job / task. A job / task review is normally conducted during the performance of the job / task if it appears that the original man-rem estimates will be exceeded. A post job / task ALARA evaluation is subsequently accomplished if the total dose expened for the job / task exceeds 8.0 man-rems or is greater than >2 times the initial estimate if the initial estimate was greater than 1.0 man-rems.
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The inspection disclosed the following:
An ALARA review had been completed for 139 jobs / task to be
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accomplished during the current outage.
The licensee has projected that the estimated exposures for 32
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jobs / tasks will be equal to or exceed 2 man-rem.
There are an additional 13 jobs / tasks for which the man-rem estimates are expected to be equal to or exceed 1 man-rem.
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The man-rem expenditures for 43 jobs / tasks were already
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completed at or below the projected man-rem estimates.
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At the time of this inspection, the man-rem estimates for three jobs /taks having the potential for high exposures had already been exceeded. The jobs were identified on Radiation Work Permits (RWP)83-705, 83-807 and 83-808.
They involve refueling preparation work, radiation surveys of the containment and decontamination of containment work areas. The initial man-rem estimate for refueling preparations was estimated as 2.0 rems. Approximately 8.497 rem had been expended at the time of this inspection.
Discussions held with
the ALARA engineer revealed that a re-evaluation of the initial estimates would be accomplished.
The man-rem expenditure for steam generator eddy current and hydrolancing were expected to be approximately 70% below the initial man-rem estimates projected for the job. The actual eddy current of "A" steam generator was completed approximately
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three days ahead of schedule. The results of eddy current operations did not disclose any defective steam generator tubes.
Mock-up training for steam generator work was accomplished.
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The licensee has commenced their 10 year In-service inspection
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(ISI). Dose projections for ISI work in the containment, auxiliary and fuel handling building have been estimated as 54.125 rem.
A total of 1.212 rem has been expended to date.
ISI work is the highest exposure job scheduled for this outage.
The second highest is steam generator eddy current and hydro lancing operations.
Reactor vessel head removal was scheduled to occur on Sunday
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March 27, 1983 or approximately one week ahead of the initial schedule.
The inspector observed that sufficient supplies and human resources were available to conduct work related to the outage. Ample supplies of anti-contamination clothing were stored at various locations within the controlled areas of the licensee's facility.
Portable dose rate survey meters, air samplers and friskers were available throughout the plant.
Portable instruments examined by the inspector during the tour were within the calibration due dates.
An evaluation on the effectiveness of the ALARA program between 1981 and 1982 was determined by the licensee. The results of this evaluation indicated that the average man-rem expenditures for 1982 were 25% lower than for 1981 despite the fact of the bad fuel that resulted'in higher radiation levels.
The inspection disclosed that the licensee's ALARA program appears to be consistent with the guidelines and recommendations of:
Regulatory Guide 8.8, "Information Relevant to Ensuring that
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Occuptational Radiation Exposures at Nuclear Power Stations will be ALARA".
Regulatory Guide 8.10, " Operating Philosophy for Maintaining
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Occupational Radiation Exposures ALARA (Nuclear Power Stations)".
No items of noncompliance or deviations were identified.
c.
Personnel Contaminations The inspector examined licensee records associated with the numbers of personnel skin and clothing contamination occurrences.
Personnel contamination records for the period January 1 through March 24, 1983 were reviewed.
All personnel contaminations are investigated and documented by the radiation protection staf f immediately af ter their occurrence.
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Facial contamination in the area of the mouth, nasal passage and open wounds are followed up with a whole body count.
Probable causes and corrective actions taken for each occurrence are included on each personnel contamination report.
The numbers of personnel contamination reported during 1983 were 13 clothing and 5 skin contaminations. An an.aal comparisons of personnel contamination occurrences for 1981 and 1982 was accomplished by the licensee. The comparisons indicate that skin contaminations and clothing contaminations for 1982 dropped by approximately 60% and 52% respectively. The inspection also disclosed that management has established goals and taken action to instruct the staff to maintain skin and clothing contamination as low as is reasonable achieveable. The inspector commended the license for their efforts in reducing personnel contamination occurrences.
No items of noncompliance or deviations were identified.
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Exposure Control Exposure records of individuals selected at random were reviewed to determine compliance with the regulatory requirements expressed in 10 CFR 20.101, " Permissible Doses", 10 CFR 20.102, " Exposure History, 10 CFR 20.103.(c).(2)e.g. bioassys and 10 CFR 20.202,
" Personnel Monitoring" A tour of the licensee's facility was
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conducted in conjuction with this review to confirm the licensee's exposure control practices. Licensee procedures describing their j
dosimetry program and exposure control practices were also reviewed
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to determine compliance with the regulatory requirements. The following procedures were reviewed:
Number Title
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GLAI 100-16Q TLD Issuance and Data Records for Personnel Radiation Dosimetry at PGE.
1GLAI 100-18Q Whole Body Counting Instructions APT WBC-6000
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Three Crystal Counter.
GLAI 100-22Q Regular TLD Badge Exchange.
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GLAI 100-30Q Harshaw TLD Reader Model 2000c Operating
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Instructions.
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GLAI 400-2Q Test: Evaluation of Harshaw TLD System.
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GLAI 400-10Q Test: TLD Response to Steam Generator Beta Gamma Radiation.
GLAI-400-12Q Test: Shielding Effects on Steam Generator
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Beta Dosimetry by Anti Contamination Clothing.
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GLAI 400-16Q Test: Evaluation of Harshaw TLD Reader
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Model 2000c.
RP-106 Whole Body Counting.
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RP-106.1 Whole Body Counting, Thumb Rules.
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RP-109 Personnel Dosimetry Program.
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RP-109.1 Exposure Control for Steam Generator Work.
RP-119 Airborne Radioactivity Sampling and Analysis.
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RP-120 Radiological Control for Steam Generator
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Maintenance.
The licensee's dosimetry program remains essentially the same as what is described in Section 11 of Inspection Report 50-344/82-04.
The results of tests performed pursuant to GLAI 400-10Q, GLAI 400-12Q and GLAI 400-16Q were reviewed. The purpose for these tests a're defined in the title heading of each procedure. The results of these tests verified the accuracy and response of the licensee's dosimetry equipment and indicated that the shielding effects on the beta dose by anti-contamination clothing was significant. The data did not indicate any change in the gamma dose while the beta dose showed a reduction of approximately 50% due to the shielding provided by the polyethylene air hoods.
The review of personnel exposure records revealed that multiple dosimetry consisting of whole body and extremity monitoring devices were used for determining the exposures received by steam generator workers. The highest exposure recorded from the miltiple dosimetry processing is assigned to the steam generator workers exposure records. The review further revealed that the penetrating and nonpenetrating exposure levels received by workers were within the regulatory limits prescribed in 10 CFR 20.101.
The licensee has also implemented a whole body counting program for determining internal contamination levels. Whole body counting is normally performed at the beginning of employment, annually during employment and upon termination.
Additional whole body counting is performed when there is reason to suspect internal contamination. The whole body counting program provides information regarding internal contamination of the thyroid, lungs and lower torso.
A review of whole body counting records conducted by the inspector verified that there were no cases of internal contamination of workers.
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The inspection disclosed that the licensee's exposure control program for determining whole body and internal exposures are consistent with established plant procedures and the regulatory requirements.
Improvements in the maintenance of personnel exposure records were observed by the inspector.
No items of noncompliance or deviations were identified.
e.
Surveys A review of surveys for radiation (gamma and beta) and airborne particulate radioactivity in effluents for steam generator and day to day operations was conducted for the purpose of determining the adequacy of the licensee's external and internal exposure control program and for compliance with 10 CFR 20.201, " Surveys" and 10 CFR 20.401," Records of surveys, radiation monitoring, and disposal."
Radiation levels measured in the A steam generators were:
20 r/hr gamma on contact with the tube sheet, 12 r/hr gamma in the center, 8 r/hr gamma at the manway opening and I r/hr gamma at 18 inches from the manway. The beta exposure levels were 100 rads /hr on contact with the tube sheet and 40 rads /hr in the center.
Survey records of particulate radioactivity in effluents for steam generator work and the day to day operations did not disclose any unusual results. The inspection disclosed that the licenset's surveys program for determining airborne particulate radioactivity in effluents appeared to be consistent with 10 CFR 20.201, and appears to meet the intent of 10 CFR 20.103, exposures of individuals to concentrations of radioactive material in air in restricted areas. Survey data was well documented.
No items of noncompliance or deviations were identified.
3.
Tour The inspection included a tour of the licensee's facility.
Independent radiation mearurements were conducted during the tour. The measurements were obtained with a Keithley, Model 36100 ion chamber survey meter. The instrument was last calibrated on October 19, 1982.
The licensee's control of radiation areas and high radiation areas appeared to be consistent with 10 CFR 20 requirements.
Most of the postings had dates in late March. The radiation levels noted on the postings were comparable to those indicated by the NRC instrument except for two areas. The inspector observed that radiation and contamination levels were not denoted an postings that were established around two loaded spent resin liners located in the Crane Bay Area of the auxiliary
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building. Additionally the' radiation levels denoted on postings in the locked radioactive material storage area located on the 93 level of the refueling facility was much lower (e.g. 10 mr/hr verses actual general area readings ranging to 70 mr/hr) than indicated by the NRC instrument.
Both the Crane Bay and radioactive material storage areas were verified to be incompliance with the regulatory requirements. The findings were discussed with the radiation protection supervisor and at the exit inte rview. The radiation protection supervisor took immediate action to update the postings and instructed his staff accordingly.
Reviews of several RWPs indicate that dosimetry, protective clothing, respiratory protection and special instructions appeared to be commensurate with the conditions observed on the tour.
Radiologically contaminated areas were posted and segregated from non-contaminated areas by a step off pad and rope barrier.
Large portions of the auxiliary building and refueling facility are accessible without the need for anti-contamination clothing.
No items of noncompliance or deviations were identified.
4.
Training The inspector examined the licensee's General Employee's Training (GET)
program. The examination included inspector observations of GET
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conducted during this inspection, discussions with the licensee's staff and a review of training records, lesson plans and Administrative Order (AO-9-1), " Personnel Indoctrination".
A0-9-1 establishes the licensee's GET program for all individuals requiring unescorted access to the Trojan Plant.
A0-9-1 details the specific training that is provided as well as the frequency for conducting retraining. A review of the A0 revealed that it establishes a GET program that is consistent with 10 CFR 19.12, " Instructions to Workers" and Technical Specifications, Section 6.4, " Training".
Section 6.4.1 of the T.S. requires the licensee to maintain a retraining and replacement training program that is consistent with or exceeds the requirements and recommendations of Section 5.5, lietraining and Replacement Training" of ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel". The GET program provides training in the following areas:
Radiation Protection
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Prenatal Radiation Exposure
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Sefety and Fire Protection
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Emergency Plan Response
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Security
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Quality Assurance
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Respiratory Protection (As needed only)
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The GET may consist of the video tape presentations (previously described in Section 6 of Inspection Report 50-344/81-02) or a live lecture.
. Handout reading material is also provided to all participants attending the training. An examination is administered to all persons receiving this, training. Normally the live presentation is only provided in January and February of each year for the plants permanent staff. The video tape presentation is generally provided the remainder of the year.
The inspection disclosed that both the video tape GET program and live
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The live presentation of the GET program does not appear to be as well organized and documented as the video tape presentation.
Administrative Order (AO-1-5), " Technical Services" assigns the Training Supervisor the responsibility for administration and implementation of all training activities conducted at the plant. Among these responsibilities is the implementation of the GET program. The inspection and discussions disclosed that formal instructions and/or procedures defining the training group polices and requirements for implementing the assigned responsibililties of the A0 have not been clearly defined.
The inspection disclosed that the live presentation of the GET program for the licensee's permanent staff was conducted in January and February of 1983.
Staff members from the licensee's Training, Q.A., Safety, Security and Radiation Protection groups conducted the training. The lesson plans used for this training were not formally reviewed and approved by the training group and nor did the training group maintain a copy of the lesson plans on file.
A review of lesson plans used by the radiation protection and training groups was conducted to determine if the course content was consistent with the regulatory requirements. The review revealed that the lesson plan prepared by the training group, entitled, " Radiological Emergency Response Plan", consisted of a brief handwritten outline with notes scribbled on it; whereas, the lesson plan prepared by the radiation protection group was more formal and provided much more detail. Neither lesson plan includes all of the material that is covered in the video tape presentation. Discussions with the training supervisor disclosed that the " Radiological Emergency Response Plan" lesson plan was used to appraise personnel on the administrative controls for working in areas where the evacuation / paging system is inaudible. A review of this lesson plan outline disclosed that it does not clearly reference the actions personnel are to take while working in high noise areas; whereas, the video tape presentation concerning Safety and Fire Prevention provides clear and concise instructions on this item.
Concerns with respect to this item are discussed in Section 3(b) of Inspection Report 50-344/83-05.
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The need to evaluate the live presentative GET program was emphasized at the exit interview. Additionally, the need to improve the coordination and to formalize the implementation of training group responsibilities was discussed with the training supervisor and at the exit interview.
No items of noncompliance or deviaticus were identified.
5.
Exit Interview The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 25, 1983. The inspnctor summarized the scope and findings of the inspection. The inspector informed the licensee that no items of noncompliance or deviations were identified.
The following matters were brought to the licensee's attention:
a.
The need to evaluate and coordinate the live and video-tape presentations of the general employee's training courses for consistency, course content and to assure compliance with the regulatory requirements. The need to improve the coordination and formalize the implementation of training group responsibilities, policies, and requirements was also discussed.
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The need for instructing RPTS to conduct appropriate surveys and update posting as radioactive materials are cove into or removed from work / storage areas.