IR 05000348/1980041
| ML20126G097 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/10/1981 |
| From: | Gibson A, Hosey C, Perry W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20126G083 | List: |
| References | |
| 50-348-80-41, 50-364-80-52, NUDOCS 8103260370 | |
| Download: ML20126G097 (26) | |
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NUCLEAR REGULATORY COMMISSION
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a REGION 11
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101 MARIETTA ST., N.W.. SulTE 3100 ATLANTA, GEORGIA 30303
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' I Report Nos. 50-343/30-41 and 50-364/B0-52 Licensee: Alabama Power Company P. O. Box 2641 Bi rmingham, AL 35291 Facility Name: Farley Docket Nos. 50-348 and 50-364
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License Nos. NPC-2 and NPF-3 Inspection at: Farley; site near Ashford, Alabama Inspectors: M GW
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C. M. Hosev Date Signec
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Sh&lr/
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sw W. Perry
Date' Signed r
Accompanying Personnel:
W. T. Bartlett, Battelle Pacific Northwest Laboratories
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I. C. Nelenn, Battelle Pacific Northwest Laboratories
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J., L. Mi ins, Radi.ological Assessment Branch, NRR Approved by:
ii dbm Obhl A. F. Gibson, Chief, Tecnnical Inspection Branch Date Signed l
Engineering and Technical Inspection Division Dates of Inspection: December 1-12, 1980 SUMMARY Areas Inspected This special announced inspection involved 356 inspector-hours onsite.
The
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following areas were included as a part of the Health Physics Appraisal: radi-ation protection organization and management; personnel selection, qualification and training; exposure controls; ALARA program; radioactive waste management;
.and, f acilities and equf pment.
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Results l
Of the six area's inspected, no apparent violations or deviations were identified in five areas; one apparent violation was found in one area (failure to follow crocedures for release of systems for maintenance).
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DETAILS
'1 Persons Contacted
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Licensee Employees
- W. G. Hairston, III, Plant Managar
"X. W. McCracken, Technical Superintendent
- C. O. Nesbitt, Chemistry and Health Physics Supervisor P. Fa nsworth, Senior Health Physics Foreman e
"J., M. Walden, C&HP Sector Supervisor
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W. Gripentog, C5HP Sector Supervisor -
"M. W. Mitenell, C1HP Sect:r Su;ervis:r L. S. Williams, Training Superintendent
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D. Herrin, Licensing.
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D. Morey, Operations Superintendent H. R. Garland, Maintenance Supervisor
"J. W. Kaie, Jr., Coerations Cuality Assurance Engineer W. C. Carr, Plant Quality Assurance Engineer-J. W. McGowan, Manager, Operations Quality Assurance (Corporate)
3. P. Patton, C&HP Sector Supervisor B. Miller, Plant Training R. E. Bryant, Utility Foreman Other licensee employees contacted includeu 35 technicians, 5 operators,15 mechanics,10 security force members, and 5 office personnel.
NRC Resident Inspectors
'W.H.' Bradford, Senior Resident. Inspector
- J. P'. Mulkey, Resident Inspectori
- Attended exit ir.terview 2.
Exit Interview The inspection scope and findings were summarized on December 12, 1980 with those persons indicated in paragraph 1 above.
The inspector reviewed all
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aspects of the healthfp.hysics program at the facility. This review included the radiation protection organi:ation and management, personnel selection,.
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cualification and training, exposure controls, radioactive waste management, ALARA prog. rams, and facilities and equipment.: The inspector stated that the areas of technician training, control of cross connections of tne deminera-li:ec water system with radioactive systems and isolation of plant systems
. prior to maintenance should be reeva.luated by the licensee.
The plant marager agreed to review these areas.
On December 23. 1930, additional discussions were reld between the plant manager and memcers of the Regional staff c:ncerning the plant's on-the-job training procram for enemistry and
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health physics technicians, criteria. for crediting experience in. non-tech-nician jobs toward meeting the experience requirements of technicians, and administrative controls to reduce the possibility of contaminating the deminerali:ed water system. On December 24, 1980, a Confirmation of Action'
letter was issued to the licensee confirming actions to be taken to streng. hen the training program for technicians, reevaluate the criteria used for crediting experience received in non-technician jobs, and estab-lish administrative controls of the demineralized water system. On March 13, 1981, tne plant manager was informed that failure to follow crocedures for release of systems for maintenance would be considered a violation of.NRC
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i reouirements.
3.
Licensee Actien on Previous Inspection Findings
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(0 pen) Ncncompliance (348/79-42-01) Failure to follow procedures for isolation of system prior to maintenance.
The inspector reviewed the i
corrective action taken by the licensee discussed in the licensee letter R8:RII:CMH 50-348/79-42 of February 21, 1980.
This item is discussed further in puagraph 8.c of this report.
4.
Unresolved Items Unresolved items were not icentified curing this inspection.
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5.
Listing of Violations of NRC Requiremenos and Inspector Followup Items'
No violations of NRC regulatory requirements were identified. The following is a summary tabulation 'of inspector followup items identified throughout this report.
Inspector followup items (IFI) are matters which will. be examined in future inspections.
IFI (348/80-41-01')' Criteria for crediting experience 'in non-technician jobs
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toward experience requirements of ANSI N18.1-1971 (paragraph 7).
IFI (348/80-41-02) Specific training of technicians and foremen in duties assigned (paragraph 7).
IFI (348/80-41-03) Acacemic training program for technicians (paragraph 7).
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IFI.(348/80-41-04) Techn'ician 0JT 'and qualification program (paragraph 7).
IFI (348/80-41-05) Formal retraining program.(' paragraph 7).
IFI (348/80-41'-06) CSlibration facil'ity 'for exposing TLD (paragraph 8.a).
IFI (348/80-41-07). Formal. investigation and documentation of TLD/self-reading dosimeter differences (paragraph 8.a).
IFI (348/80-41-03) Neutron exposure procedure (caragraph 8.a).
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IFI (348/80-41-09) Seta dose through respirator lens (paragraph 8.a).
IFI (348/20-41-10) N-16 exposures (paragraph 8.a).
IFI (348/80-41-11) Quality control test of vendor TLD evaluat. ions (paragraph 8.a).
IFI (348/20-41-12) Sicassay for beta emitters (paragraph 8.b(1)).
IFI (348/20-41-13) Internal dose assessment procedures (paragraph 8.b(1)).
IFI (348/80-41-14) Resotratory protection procedure changes (paragraph 8.b(2)).
IFI (348/80-41-15) Storage of respirators (paragrapn 8.b(2)).
IFI (348/80-41-16) Re spi ratory equipment issuance facility (paragraph 8.b(2)).
IFI (348/80-41-17) Control of locked high radiation areas (paragraph 8.c).
IFI (348/80-41-18) Review of HP records (paragraoh 8.c).
IFI (348/80-41-19) Personnel contamination monitoring program (paragraph 8.c).
IFI (348/80-41-20) Administrative controls for connections with Deminera-li:ed Water System (paragraph 8.c).
Violation (348/20-41-21) Isciation of systems for maintenance (paragraph 8.c).
IFI (348/80-41-22) Overflow of waste evaporators to ventilation system, (paragraph 8.c).
IFI (348/80-41-23) Safety evaluation of new solidifi : tion system (paragraph 9.c).
IFI (348/20-41-24) Waste reduction training for plant personnel (paragraph
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9.d).
IFI (348/80-41-25) Isolation o,' dry waste compactor (paragraph 9.d).
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IFI (348/80-41-26) Cevelopment r,f documents to train pe, sonnel in proper
- libration of fixed monitors (paragraph 9.d).
IFI (348/20-41-27)~ Incorporation of ANSI N323-1978 into instrument calibra-tion program (paragraph 11.b).
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c.
Radiation Protection Organization and Management The Appraisal Team reviewed the plant's radiation protection organization and how it relates to the overall plant organi:ation. The radiation ; ro-tection program at the plant is managed by the chemistry and health physics supervisor who reports to the superintendent of tecnnical services.
The chemi stry and health physics supervisor has direct access to the plant manager regarding radiation protection matters. Nu apparent problems with this reporting chain were identified by the Aopraisal Team, but this is considerad to be strongly dependent on the individuals involved and should be reevaluated if cersonnel changes are mace.
The health physics staff under the chemistry and health physics supervisor
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is as shown in figure 1.
In addition to the section s;;ervisors and fore-men, the Chemistry and Health Physics Group (C&HP) has 40 C&HP technicians, 4 radiation detection men, and 30 nuclear operatives. A health physics foreman is on-duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week.
In addition, select senior C&HP personnel serve as emergency HP managers on a rotating basis and are on-call to assist the duty HP foreman.
The scope of responsibilities for the radition protection program is defined in the licensee's Health Physics Manual. Specific duties and responsibili-ties for the C&HP Group are contained in plant administrative and radiation control procedures.
The inspector discussed the audit program relating to radiation orotection with licensee representatives and reviewed the following audits of the plant which were performed by the operations quality assurance group (00A):
Report 80/18, Radiological Contro-1 s,,0ctober 15 - Novemoer 14, 1980 Report 80/9, Qualifications and Training, April 29 - June 2,1980 Although most on-site audits performed by 00A personnel were procedural in nature, and were performed primarily to identify and correct noncompliances, reviews or assessments of the effectiveness of the plant's radiation pro-tection program are performed. On July 23-30, 1980 an evaluation of the plant's nealtn pnysics program was performed by senior memeers of the licensee's corporate office.
In addition an assessment of tae plant's health physics program was performed on Novmeber 21-24, 1980 by an outside
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vendor with expertise.in radiation protection matters.
Summary:
Based on the above findings, this portion of the licensee's program appears to be acceptable.
7.
Personnel Selection, Qualification and Training Health Physics Staff Selection and cualification criteria for each of the cositicns in the
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radiation orctect cn organi:ation have oeen documented in plant orocedures
FNP-0-AP-17, Ccaduct of Operations Chemistry anc HP Grouo, anc FNP-0-AP-3,
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Plant Organi:ation and Rescensibility. Experience and educational require-ments are included in these selection criteria. These criteria are used in
the formal selection prccess, and personnel are generally aware of the
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criteria.
The C&HP Supervisor promotes the com;any :hilos0chy of hiring permanent staff wne have at least 2 years of college crecit.
Tnere is a strong tencency to try to re.ain qualified staff an.1 to fill tecnnical positions with existing staff. As an example, personnel with Bacnelor's degrees in physics are preferentially selected to fill vacancies cccurring in the counting laboratory. The3e persons have tne funcamental tecnnical training to advance to supervi sory positions in the Environmental anc Emergency Planning Section of the HP crganization.
Persons with U.S. Navy nuclear ex:erience are preferred for HP tecnnician
- csitions. The existing HP staff has a great deal of nuclear Navy experi-ence, and therefore, Navy experience is reviewed very critically. Attentien is fccused on retaining cersons with actual radiation meni Oring ex
- erience.
In lieu Of actual ex:erience and technical train rg, persens ai n college level scientific training are preferred.
Job acplicants sith neither HP experience nor scientific train 11g are usually placed in posit'ons as " nuclear operatives". The nuclear er,erative is all0wed to function only in specifiec jobs, but opportunities are given for HP training and advancement to the HP technician ranks.
Temporary centract HP technicians are selected according to a formalized p rec ecure. Those selected must meet the requirements of ANSI N18.1-1971. A form is used to cocument the amount of experience and training of each applicant. After selection, a contract. HP technician is only allcwed to perform. those procedures for which he has been qualified by the HP staff.
The qualifications of the Chemistry and Health Physics Supervisor (radiation protection manager) were evaluated against the recommendations found in Regulatory Guide 1.8, September 1975 and found to be adequate.
Re:orting directly to the Chemistry anc Heal:n Physics Supervisor was the Health Physics Section Supervisar who had over 25 years experience in health physics monitoring and health physics supervision. He also met the require-
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ments of R.G.1.8 for a radiation protection manager.
TL qualification of all section supervisors and HP foremen were reviewed and found to. meet or exceed the appropriate requirements set forth in ANSI N18.1-1971. In general, the inspector f:und the staff positions were filled by very well qualified persons.
At the time of thi irs ection, the plaat was in an cutage. Over 30 centract MP tecnnicians nad :een hired :: su::lement the routine HP pr: gram.
The resumes of all c rt-act anc ce-anently em:1cyec HP tecnnicia-s were reviewed. TFe HP Secti:n Su:ervis0r ard tre C&r: su:ervisor were als:
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questioned on methods used to cualify these technicisas.
The review of resumes clearly indicated that "non-monitoring" HP experience was often disallowed, that academic training was carefully reviewed as appropriate to HP technician qualification, and that Navy nuclear experience was not unquestionably accepted as HP technician experience.
While reviewing the experience of the plant's permanent health pnysics technicians, the inspector notad that the plant had no criteria for assigning credit for experience received as a nuclear ocerative or radiation detection man toward the experience requirema..ts of ANSI N13.1. A review of the job description and actual tasks performed by individuals with these job tities indicated that very little of the experience can be used to meet the ANSI N18.1 experience requirements. The inspector stated that the licensee should reevaluate the criteria used for crediting ex;erience as a ractaticn detection can or nuclear operative in meeting the exoerience requirements of ANSI N13.1-1971 for chemistry and health physics technicians (343/30-41-01).
Plant procedure FNP-AP-17, Revision 2, Conduct of Operations - Chemistry and Healtn Physics Group, specified that HP technicians must comolete tne realth pnysics training course before they are consicered qualified technicians.
Two incividuals did not comiete the HP training course. One individual was the foreman assigned the responsibility for decontamination of equipment and facilities. The licensee has no minimum training or experience requirements for C&HP foremen. The inspector stated that health physics foremen should, as a minimum, complete the health physics training course required of HP technicians.
The other individual was a lead technician responsible for portable instru-ment calibration. The individual appeared to h6ve a good knowledge of the
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mechanics of instrument calibration, however, he did not have a good under-standing of tne fundamentals of radiation detection and the calibration techniques recommended in ANSI N323-1978. Although the technicians work was reviewed by a health physics foreman, he and other individuals assigned specific responsibilities, such as whole body counting, instrument calibra-tion, insoecting, etc., should receive specific training in the duties
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assigned (348/30-41-02).
Ouring the review of health physics technician duties, it was noted that the licensee has not formally. determined what duties or tasks performed by
.I technicians require the technician to be ' ANSI qualified.
The inspector
~1 stated that: the licensee should formally establish when a technician is performing in a responsible position and thus should be ANSI qualified.
All HP technician trainees are required to attend a basic health physics training course given by the plant's training group.
In the past, this course consisted of 5 to 6 weeks of continuous classrocm training.
During 1980, the initial HP training was spread out over the entire year and consisted of one week training sessions given aoproximately monthly.
Guidance for the HP training course can be found in FNP-0-AP-45, but this pr0ceture only outlines lecture topics to be presented in tne HP training.
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The inspector questioned the training supervisor concerning the planning of HP technician training. At present, a new training plan is being develooed.
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Instead of a protracted HP training scnedule, the initial training will be completed in a 5 to 6 week period. At the time of the inspection there was no formal lesson plans, very few handouts to students, and no training manual.
The initial HP training was not linked to an on-the-job training schedule, and technicians had complained of the lack of lacoratory exercises or actual in plant training sessions. There was no instructor availaole to plan or implement enanges to the existing program. The inspector stated that aopropriate staff should be assigned to develop and imolement an ef fective HP technican training program.
The academic training program for technicians needs to ba better organized and should incluce development of fccmal lecture plans, establisneent of performance ocjectives (methods of evaluatien), ceveicoment cf training manuals, and pre-course assessment to cetermine if students have the basics to succeed (348/B0-41-03).
There was no formal en-the-joo training (CJT) or cualification program for HP tecnnician trainees. They are required to attend the Farley HP techni-cian training course, review and become proficient with HP procedures, and perform monitoring duties for a period of time commensurate with the ANSI N18.1-1971 standard. There are no coals, time tables, or testing to indi-cate progression in the OJT program. The inspector stated that an on-the-job training and qualification program should be formalized with definite progression goals leading to the status of " responsible technician" (348/
80-41-04).
In FNP-0< AP-45, Appendix G, retraining of ur acalf is required, but this retraining :is at the. discretion of the C'atP supervisor. Most of the HP supervisory staff have been sent to' the basic radiological protection training courses at Oak Ridge Associates Universities.
In addition, selected staff have attended respiratory training programs.
Ctner courses attended are simply auditing the basic HP technician training courses. The inspector stated that a formal retraining program designed to maintain the proficiency of the entire Health Physics staff should be established (348/
80-41-05).
Two fulltime.HP instructors were employed by the training section.
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instructors were found to have adequate academic training and experience as HP technicians and as-instructors. Both individuals exhibited a high level of enthusiasm for their responsibility wnich was the general staff HP orientation. training program.
The contents of the HP orientation training were reviewed and found to ce adequate. All persons requiring access to the plant must attend the crien-i tation training. Dersons with obvious HP experience are given an abbrevi-ated form of training which includes site specific f rformation. All persons are required to take a written test composed of multiple choice and short
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answer questions. Because of the short answers on the test, the instructor can easily determine if pracical information (such as dressing in protective clothing) was understood. If test responses are not adequate, the instruc-tor may require each individual to respond vercally. He may also require individuals to dress in protective clothing or demonstrate proficiency in practical procedures.
If persons cannot adequately read or comprehend information presented in the HP orientation, they are denied access to the
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plant.
Although the HP orientation training requires 2 full time instructors, benefits have been observed. There is increased efficiency in entering and exiting contaminated areas, and consequently better contamination control.
In addition, emphasis on HP orientation and management support of this function have helped improve the staff attitude toward radiation protection.
Summary:
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
a.
criteria for crediting experience as Radiation Detection Man and Nuclear Operative in meeting requirements of ANSI N18.1-1971; b.
minimum training and experience requirements for C&HP foremen; c.
training and qualification requirements for individuals performing rpecific tasks (e.g., whole body counting, instrument calibration, etc.);
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define " responsible positions" as it' applies to technician qualifi-cations; upgrading academic traintag. program for technicians; e.
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establish formal on-the-job training and qualification program for technicians; and g.
formal retraining program for C&HP staf f.
8.
Exposure Control
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External Exposure Control-The basis for the exts nal exposure control program is contained in the chealth physics manual,. revised October 23, 1980.
Procedures specific to exernal exposure control are contained in Radiation Control Proce-dures FNP-0-RCP-8, Personnel Monitoring, revised December 4, 1980.
External exposure _is controlled as low as reasonably achievable within 10 CFR 20 limits.
Physical control over entry into high radiation
- enes, use of radiation work permits to maintain worker control by HP
personnel, containment entry permits and use of administrative limits including ALARA review are included in the program to avoid over exposures of personnel.
The licensee relies on a vendor TLD system for determining external radiation exposures for compliance with 10 CFR 20. An additional plant TLD is assigned i' the individual is not expected to receive more than 10*; of the 10 CFR 20 limits (to confirm that such limits are not exceeded). Except during an outage, vendor TLDs are read at the vendor facilities. During outages a vendor representative reads the TLDs for those wnose pocket dosimeters indicate an accumulated cose of 200 me for.the cadge period.
Vender TLDs are read for both beta and gamma exposures. The means of calibration of vendor TLDs were not determine curing the site visit. Whether :r n:t the vendor OA pr: gram confermed to the draf t ANSI Standard N13.11 was also not determinec.
Plant TLDs are calibrated using a Cs-137 source and an R meter whose calibration is traceable to N95.
The calibration f acility including
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the room and the apparatus for ::sitioning source and TLD, are aceouate for the plant TLD program, but are aopraised as inadecuate for exposure measurements of record.
The licensee has indicated that it will establish an in-house TLD program in the near future.
The inspector stated that the calibration f acility be carefully planned and incor-porate suggestions to be found in Draft ANSI N13.11.(348/80-41-06).
In addition to the two TLDs worn, self-reading pocket dosimeters in the range of 0-200 and 0-1000 mrem are issued singularly or together as appropriate. pocket dosimeters are issued with security badge and TLD prior to entry to the protected area.
Entry into a radiation controlled area requires filling out a form on which the pocket desi-meter reading is recorded prior to entry and after leaving.
The current exposure status is posted daily for review by the worker prior to entry into the radiation control area. The licensee has experienced a significant loss of pocket dosimeters. The reason for this is not understood.
However, the licensee is conducting an investigation to determine the cause and will develop a cost effective control system.
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formal documentation' of reconciliation.. of differences as a result of the exposure investigation. The.: inspector stated 'that the exposure investigation.and documentation of the results should be formalized at i
least for, exposures down.to 100 mrem and where difference between pocket dosimeters and TLDs exceed 25% of the TLD reading. The invest-igation should include a' review of stay times and dose rates, check of dosimetry devices and exposure. recorded for,other personnel performing
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similar work (348/30-41-07).
Neutron exposure is cetermined by t me keeping and cose rate measure-i ments. Calibration of neutron survey instruments is done using a ?uSe
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source. Exposures are kept to less tnan 300 mrem / quarter to Obviate l
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-the requirement for dosimeter - use.
Although -film: dosimeters are '
required by procedures, it is recognited, that film..is useless for l
neutron -measurement.in the energy range encountered..The inspector stated that the procedure should be revised to reflect the current procedures (348/80-41-08).
The licensee has some concern.for beta dose' to the ' eye during. eddy.
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current testing of, steam generator tubes...An experiment was performed
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to determine tne attenuation of beta particles incident on the worker's lexan respirator lens. The' result suggested a factor of approximately 6.
The ' investigation is not complete..However, the expedient _of.
doubling the lexan'. lens thickness is believed: to. be capable of. obvi-ating essentially all beta dose to the eye. As understood, it is not that beta dose te the eye is limiting, but that the licensee needs to.
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assure himself that beta dose would not inadvertently become an undis-closed health'ha:ard (348/80-41-09).
The licensee has not consi_dered possible exposure.- from N-16 photons.
l The licensee should investigate areas of the~ plant where N-16 may be -
present (348/80-41-10).
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According to RCP-3, once a quarter, a vendor TLD will be exposed to a known exposure as an in-house QA test. The appraiser concluded.that to be meaningful and to give the licen ee 'the degree of confidence.
desired, not less than five TLDs should be so tested and preferably on a monthly, rather than quarterly schedule (348/80-41-11),
All external dosimetry records are maintained by individual on computer files.
Records ' of exposure incidents and other pertinent data are contained in individual file. folders.
Records of TLDs processed ~and
other data'are also.kept on microfilm in document control.
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b.
Internal Exposure Control
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(1) Monitoring Whole bocy counting is provided onsite and provision is made for
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urinalysis by an independent laboratory.
There are no routine
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bioassays (excretion analysis). Operation and calibration of the
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whol.e body. counter l is described in plant procedure RCP-9, revised
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> November 5, 1979, ' Bioassay sampling is describec in RCP-13.
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Operators of the whole body counter are trained on-the-job.
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The whole body counter system uses a three-detector, chair-style whole body counter. Each detector.is calibrated for the following
' j radionuclides: Cr-51, I-131, C s-134,. C s-137, Co-58, Mn-54, Fe-59, 2n-65, and Co-60.
A representative lower limit of detection,
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t expected for Co-60 in the lungs and abdomen is 1 nC1; for Cs-137 ir the lungs and abdomen 2nC1. The lower limit of detection for I-131 in the thyroid is 0.5 nCf.
The counter is calibrated
i annually a:corting to procedure RCP-3 using NBS traceable sources
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for the radionuclides noted above.
The most recent calibration was performed on Cecember 2,1980.
Although the computer calculates body burdens for only the stand-ard nine radionuclides, a graph of the counter per channel is reviewed by the technicians.
In one instance, the presence of Se-75 in an individual was quantified by manual analysis of the multichannel analy:er output. The isotope had been administered by a physician for scanning of the pancreas.
The licensee participated in an'NRC soiked phantom study; results for Co-57 and Co-60 were reasonably close.
However, the Cs-137 estimate was twice the spike value and 0.58 nCi of Cs-134 in the phantom was not reported.
Whole body counts are taken on individuals prior to issuance of dosimeters and entry into a radiation control area, at termina-tion, and as deemed appropriate by HP.
Although not seen as a procedural rec ui rement, notice is given on the Radiation Work Permit that a W3C is required in the event of nasal smears (rou-tine procedure after wearing a respirator) exceeding 200 d/m.
Whole body counts are also conducted on an annual schedule.
However, the procedure for HP activities (RCP-1) simply calls for
" periodic" whole body counts. There appears to be a reluctance on the part of the licensee to be specific in some procedures because of the concern that they may be required to follow the procedural requirements. Since procedures lose effectiveness without speci-ficity ~ the licensee should consider having procedures state specific requirements.
In' RCP-1,' bicassay' urinalysis (for gross beta, gamma and Tritium)~
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is called for " periodically".
Bioassay urinalysis is also required when expected body burdens exceed 10% of a maximum permissible body burden (MPB8) (RCP-S).
It is understood that such levels have not been experienced at the plant. Urinalysis af ter a WBC detection of fission or activation products appears reasonaole if, for example, Sr-90 or P-32 are expectec as a result
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of the presence of gamma emitting radionuclides.
Urine samples are to be sent to a vender for analysis. There was no evidence
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that.the. procedure of bicassay analysis and measurement interpre-tation in terms of body burden and organ dose had been tested by the licensee. The inspector stated that if the licensee believes
.there is. a potent.ial for inhalation or ingestion of beta emitters present, the bicassay system should be tested at icvels of about 10% of a MPSB.
If evidence can be shown that bicassay is not
.needed, a. summary statement to that effect shculd be given in the procedure and fbrther reference deleted.
Urinalysis for radio-nuclides whose presence in the body can be adequately followed by whole body counting snould not be required (348/80-41-12). Li ttl e
attention has been given to the calculation of doses from organ burden asoects of internal dosimetry. The inspector stated that both training in and procedures for conversion of body or organ content of radionuclides to dose should be provided.
Upon obtaining a more complete understanding of the interrelationship be cween organ-content-and-dose, procedures should be prepared for in-house use (348/80-41-13).
(2) Respiratory Protection Program A management policy statement is given in Section I, Respiratory Protection, of the Health Physics Manual, revised Octooer 23, 1980.
Conformance to 10 CFR 20.103 is specified.
The respon--
sibility for the respiratory program rests with the Health Physics Section Supervisor.
Procedures for respiratory protection are detailed in RS-101, Use and Testing of Re spi rato ry Equipment; RCP-102, Selection of Respirators for Radiological Applications; RCP-101, Maintenance and Care of Respiratory Protection Equipment; RCP-4, Operation of AIR Tank Cascade Recharging System; RCP-106, Use and Operation of Full Face Filter Type Respirator; RCP-150, Operation of Qaunti-tative Man-Fit Test Booth and others.
In addition to 10 CFR 20.103, RCP-101 also references NUREG 0041 and ANSI Z88.2-1969.
Procedures dealing with respiratory protection were reviewed.
Some errors of fact and some steps requiring clarification were brought to the ' attention of the licensee.
Examples of such include RCP-101,' Section 4.5 and RCP-102, Section 4.2 where self-contained breathing apparatus is said not to be used in
. atmospheres containing less than 19.5% oxygen; Sec.15.2.1.5 and else>nere,' reference is made 'to a zero protection factor (the
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protection afforded is zero, but the factor is unity); and, Sec. 5.2.4, the equation for calculating stay time in a contami-nated atmosphere was incorrect (348/80-41-14).
Initial worker trainng consisted of several hours of lecture on tne need for, use of, and demonstration of respiratory protection equipment. A written test was given at the conclusion of the training. Mask fitting was done quantitatively in a test booth.
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.Two individuals were tested at. a time.
Both physical exercises were performed and attempts at communication between masked Sdividuals were made.
Before mask fitting was done, a lung function test was' required. A complete physica-1 enmination is s
conducted on plant employees by physicians on contract to the licensee.
' Test results were reviewed by a physician and sent to HP.
Two profile photographs are taken to confirm conformance to facial hair requirements and are placed together with the mask fit record
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h in' the HP office 'for check before authorizing respirator issuance.
l Personnel not properly trained or fitted are not permitted in
areas requiring respiratory ' protection.
In unusual cases, a respirator may be issued, but'the protection factor taken is one; no protection is assumed.
As part of the respiratory protection' program, MPC-hrs of exposure are kept on each individual. The plant permits 38 MPC-hrs in any
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seven consecutive ' days.
Permissible stay-times are calculated based on the individual exposure' record, the concentration of
nuclides in the work atmosphere,'and the protection factor of the equipment.
The quantity of respirators (SCSA and Filter-type) appears to bez adequate for routine operations.
SCBA. units are located at
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different points about the facility.
It was - suggested that a supply of respirators' be outside the-RCA in the event of loss of those stored in plant as a. result of an incident.
Several HP staf f members have. received hanuf acturer's training. in maintenance and repair of respirators.
Plant air is used for air-line supplied respirators and for filling tanks. Testing of the quality of. air used for respira-
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tory protection purposes appears to be adequate.
As a result of an earlier inspection, face mask units are now
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stored individu. ally on shelves.
it was suggested that, in addi-tion, some means of rotation of respirators be made to preclude those least used from taking a set (348/80-41-15).
A The respiratory equipment issue f'acility was appraised as inade-
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quate.
The facility is a makeshift arrangement that assures neither positive control of this important equipment, nor bears evidence of management's commitment to a good respirator protec-tion program (348/80-41-16).
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I c.
Health Physics Surveillance and Access Control l
~ During plant tours, the; inspectors reviewed the licensee's posting and
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control. of : radiation.. areas,. high ' radiation areas, airborne radioac-tivity areas,, contamination areas, radioactive material areas and the labelling of radioactive. material. An inspector reviewed the admin-
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'istrative controls.in use at the plant.to prevent unauthorized access l
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to locked high radiation ' areas.
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The inspector observed that doors leading.to two high radiation. areas-(RHR heat exchanger room and Vol.ume Control Tank ~ room) were unlocked, although the signs posted on the. door stated that the doors must be
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kept locked.
Radiation levels in both rooms were less than 1,000 mrem /hr. Therefore, the rooms were not required to be locked by i
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Technical Specifications. A review Of cuality assurance aucits and the 01 ant's raciation incicent re00r: file incicatec that keecing c00rs leacing 0 locked high raciation areas (greater than 1,000 mr/ne)
10 xec has been a pr00lem.
The inspector statec :na: :ne li: nsee snould Consider revising their key centrol system 0 better 6ntr:1 a::ess :: 10cked high racia:10n areas (3:3/50-41-17).
Radiation work permits (RWe ) are the princi:al means of establishing s
raci:10gical controls for entry into racielogically centrolled areas and for work on radioactive systems. Selected RWPs were reviewec for acer00riateness of raciation Orote::10n re uirements basec uc0n w0rk s:00e,10 cati n and conditions,. The radiation pectaction recuirements specified On the RWPs 3::ceared appropriate.
During :0urs Of the plant tne ins;e:: Ors di:Cussac :ne me heds for contrulling work in raciclegically controlled areas with nealth physics personnel (plant staff and contract tecnnicians) and etner mem ers of tne clant staff. The individuals questicaed h e an adequate knewelege of :ne prete::ive cle:ning re:uire u :s, racielogical conciti:ns, work to :e performec and specific raciation work permit requirements.
The inspe Ors reviewed selected re: Orcs of radiation, contamination, anc airderne radioactivity surveys performec between N0vem:er 1,1950 arc Decem:er 10, 1950, ciscussed the survey results witn licensee recresentatives, observed technicians performing various surveys and cerformed independent radiation and 00ntaminatier surveys in ne plant.
The insce::Or noted snat RWPs and survey results are not formally reviewed by Healtn Physics supervision. The ins;:ector stated that the review recuirements for re: Orcs generated by nealth physics should be formally specified (343/80-41-13).
At the re uest Of the inspector, a licensee representative necked each ce:ector on the ;urtal monitors at the exit from the auxiliary builcing by placing a 1 uCi Cs-137 source f0ur inches away from the detector.
The monitor ala* ed as each detector was tested. The portal monitors would a;;arently detect the unauthori:ed removal of racica::ive material or gross 00ntamination en personel.
- Portal monitors were set to 00cnt for 10 seconds and alarm f f the coun:
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rate exceeded 200 00unts per minute over background. A haec anc shee monitor was the final check before leaving the radiation :0ntrol area.
This moni Or was set to al a rm. at 100 cpm Over backgrounc, wni:n is ecuivalent to the plant's release limit. The moni:Or hac no timer and few incividuals remained en the meni:Or an acequate amount of time.
RM-14/HP-210 personnel friskers were located at tne exit fr0m COntain-ment anc at vari 0us locations in tne auxiliary cuilding. The workers were encouraged :: monitor themselves as they exit areas of hign contamination levels. An ;S-M/MF-2: frisker.as locate: a: tre ext:
tu 1 cia; and workers were -ecuired 10 feisk Orior te Of tre auxilia y
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I passing through the portal monitors.
The licensee has purchased two
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liquid scintillation portal monitors.
However, at the time of the
. appraisal L the systems were inoperable. The" systems are expected' to provide increased assurance that-persoanel contamination levels are
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below the plant limit. The. inspector stated that the 11censeeT should f
consider-upgrading their personnel contamination monitoring program by
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requiring.that each employee perform or. receive, under..the direct surveillance of health physics personnel,. a whole body contamination
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survey using an RM-14/HP-210: personnel frisker or instrument of e'quiva-lenti sensitivity when they exit the protected area (348/80-41-19).
i IE Circular 80-14, Radioactive Contamination of Plant Demineralized Water (DW) System and Resultant' Internal Contamination.of Personnel,;
recommended that licensees.take actier to p* event the i nadvertent i
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introduction of radioactive materials into the CW system via' improper
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use of temporary connections, install backflow-prevention devices, and prohibit consumption by humans of plant-supplied demineralized water.
. On_ September 15, 1980, the licensee submitted a Design Change' request to install _ check valves between contaminated systems and the. deminer-alized water system, and check valv'es in the outlets of the' CW ' storage -
tanks. At the time of the.-appraisal the plant modifications had not been, performed. The plant also posted the_0W system outlet and issued i
a memo to plant workers informing them that OW was not to be used for-human consumption, nor removed from the plant for personal use. The; licensee, however, did not take interim measures that would assure that the OW system is not. inadvertently contaminated before the permanent correcti.ve action is completed. On October 14, 1980- the DW header became' contaminated a's:a result of the temporary connection of.a hose
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between the DW system (V025A) and the spent resin sto" age tank sluicing'
pump. The. hose was. reading.22 mr/hr when detected oy health physics
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'pe rsonnel. TheE concentration of radtoactive-material at' V025A wa~s-2.6 X E-05 microcuries. per milliliter.
The header was flushed..and concentration reduced to 5.0E-07 pC1/ml. The inspector stated that the licensee ' should establish ' administrative controls to assure that
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radioactive material is not inadvert'ently introduced into the. plant's
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DW system by the improper use of temporary connections (348/80-41-20).
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_ IE Inspection Report 50-348/79-42 of February.4,1980 identified an
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item of noncompliance with the plant's Technical. Specification 6.8.1,
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in thats writterr procedures 'which ' governed the release of systems.for l
l-maintenance were not followed. The. licensee indicated in a letter dated February 21, 1980, that corrective actions'ha'd been accomplished on Feoruary 8,1980. Ouring the' appraisal an _ inspector. reviewed the
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licensee's corrective action. During this review the inspector.iden-
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- tified the. following four instances which occurred.after February 8, 1980 when the maintenance work request was released for work.when the
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system or equfpment to be'. worked was not properly isolated:
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November 18, 1980, a maintenance work request for work on an RHR check valve was released, the valve was not isolated. The system was still pressurized to 138 psi with a 3,100 gpm flow through' the valve.
August 5, 1980, a maintenance work request for work on the Steam Generator Blowdown System was released, SGBD drain line valve.not properly set.
June:12, 1980, the IB waste gas compressor unloader manual isola-tion valve was not closed when the IB WGC was isolated for main-tenance. This resulted in a release of gaseous radioactivity into the. auxiliary building.
June 6,1980, improper valve position when clearing of a Tagging Operations Order resulted in a spill at the primary sample. sink.
The reactor. coolant and pressurizer liquid and steam sample lines had been isolated for maintenance.
Each of these incidents was brought to the plant management attention through the radiation incident report system; however, appropriate corrective action was not taken to prevent a recurrence.
The inspector stated that the corrective action taken was apparently ineffective in preventing a recurrence. - The inspector stated that failure of the person. releasing the work request to perform a thorough review of the work request to ensure that the lant conditions necessary for the work specif ted was in effect and failure to position valve as
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required by the Tagging Operation Order would be considered in viola-tion of Technical Specification 6.8.1 (348/80-41-21).
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An inspector reviewed surveys performed during the transfer of spent
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fuel in the transfer tube after the completion of modifications (PNC-
'78-235, Rev. 2) to the facility. The need for additional shielding was identified by 'the licensee during the initial refueling survey per-
formed in 1979.
The highest reading identified during the initial survey was 120 R/hr on the 100' elevation at a cork seam between :ne reactor building and the auxiliary building. After the plant modifi-cations had been completed the levels were reduced to approximately 100
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mr/hr..The. modificationsEappeared, to. be effective in reducing the exposure rates from' spent fuel in the. fuel transfer tube.
During the!aporaisal the inspectors observed that the piping and wire trays in the' overhead on the 100' elevation was posted as a "contam-inated area". Licensee representatives stated'that the 100' elevation and. the.121' elevation. were. contaminated when the waste evaporator
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overflowed. Water is released ~to the waste evaporator room ventilation
i when the rupture disk blows. The plant received Plant Change Notice 78-253, Rev. 2, for implementati.on on April 6,'1979. However, the
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corrective action has not been taken. A licensee representative stated that the modification had been made in Unit 2 and they would determine if the problems had been corrected prior to expending the radiation exposure necessary to modify Unit 1 (348/80-41-22).
d.
Summary: Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
(1) calibration facility for exposing TLDs (paragraph 8.a);
(2)
formal investigation and documentation of TLD/self-reading desi-meter differences (paragraph 8.a);
(3) neutron exposure procedures (paragrpah 8.a);
(4) evaluation of beta dose through respirator lens (paragraph 8.a);
(5) evaluation of Nitrogen-16 exposure (paragraph B.a);
(6) quality control test of vendor TLD evaluations (paragraph 8.a);
(7) bicassay for beta emitters (paragraph 8.b.(1));
(8) procedures for determining internal dose (paragraph 8.b.(1));
(9)
formula for calculating stay-time (paragraph 8.b (2));
(10)
storage of respirators (paragraph 8.b.(2));
(11)
respirator issuance facility (paragraph 8.b.(2));
(12) control of locked high radiation areas (paragraph 8.c);
(13) review of health physics records (paragraph 8.c);
(14) perscnnel contamination monitoring (paragraph 8.c);
(15) administrative controls for connections to Demineralized Water System (paragraph 8.c);
(16)
isolation of systems for maintenance (paragraph 8.c); and, (17) overflow of waste evaporators to ventilation system (paragraph 8.c).
9.
Radioactive Waste Management
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a.
General The waste and decontamination section within the Chemistry and Health Physics group is a separate organizational unit assigned responsibility for overall waste management as a primary function. Provision is made for reporting to plant management through the chemistry and health physics supervisor. A monthly radioactive waste report is submitted to plant management and corporate management for review. Assurance was
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received by the'. inspector from the waste and decontamination section that proper attention and support for the waste management program is provided by management, including corporate management.
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b.
Waste Processing Systems
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The wast.e evaporator system is apparently the major system causing problems in attaining design objectives. As has been the case at other nuclear power plants, the licensee has experienced difficulty in consistently maintaining the system operating efficiently enough to
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meet decontamination factor design. objectives.. This has necessitated :
recycling which may generate additional unwanted wastes to process.
This led to the decision to install a new demineralization system l to
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replace the waste. evaporator for routine uses.
The waste manager stated.that the waste'evaporato'r will be maintained and operated as an
' alternate. to the new deminerali:er system. The new Hittman deminer-alizer system has been evaluated in 'accordance with 10' CFR 50.59 and-
Regulatory. Guide.1'.143 and the. system 'is currently. being installed.
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-The' licensee's decision -to install the new -demineralizer system' was.
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influenced by informtion obtained from other power plants indicating'
i improved performance:.
The: safety evaluation projects significant reduction in volumes of waste shipped and exposure to plant. personnel.
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Although offsite-liqutd releases. are-. expected to increase 'slightly,.
increases in decontamination factors are expected to decrease the total
radioactivity in liquid discharges.
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Liquid and Gaseous Wastes f
The waste management program provides review to minimize waste and -
i diluent releases.
Employees are also given incentives to reduce
radioactive wastes by emphasis from supervision if'there is an unusual
buildup of wastes..The waste management program.is keyed to the ALARA program and there appears to be free interchange between responsible organi:ational units to actomplish this. Licensee procedures address
.c minimf:ing wastes.
In adition to the new demineralizer system described above, the licensee has plans for other improvements to
minimize wastes.
The licensee's procedures cover the movement. and discharge of liquid
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and gase.ous wastes; release-rates, alarm'setpoints, laboratory analysis
.results, compliance with Technical Spe'cification ifmits, total activity'
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released, total volume. released, valve lineup, types of samples to be.
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collected, the aralysis performed and sampling and analysis schedules.
l This was determined through discussions with the plant staff and review of the following licensee procedures:
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RCP-57 Racioactive Material and Waste Handling RCP-58 Waste Management RCP-372 Samp1;ing Points
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RCP-376 Administrative Management of Radioactive Liquids in
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c RCP-377 Liquid Waste Releases.
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RCP-378.
Preparation of Composite Effluent Samples-
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RCP-381 Gaseous Waste.Rsleases Liquid and gaseous sample locations were observed and found to provide
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. capability for collection of routine grab samples. Containment samoles are collectec remotely during operation.
The licensee has concucted
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studies including tracing of systems to determine that' potential
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l racicactive effluent pathways are monitored and/or sampled. This
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resulted in several improvements including the turbine building sumps where liquid. level measurements, recirculation capability prior to j
sampling and improved sampling equipmen: have.been provided.. Records and discussions indicate that waste equipment is adequately maintained ~
and operated. The waste evaporator has been an ongoing problem and disproprotionate effort has been required to maintain efficient oper-ation of this equipment. Even so, there has been a definite downward trend in waste volumes.
d.
Solid Waste Processing Cbservation of shipping. containers, review of' shipping papers, review i
of. licensee procedures and discussions with111censee representativesL indicate.that. waste packaging conforms to Cepartment of Transportation and NRC regulations.
The licensee's procedures contain requirements for meeting 00T regulations. Licensee records contained certifications of shipping containers. The licensee's procedures contain requirements
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for burial sites including the absence of liquids. The licensee plans-
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to install a new Hittman solidification system and the equipment was arriving onsite at the time uof this appraisal. The safety evaluation under 10 CFR 50.59 was in progress.
The inspector stated that the safety evaluation will be reviewed during subsequent inspections (348/80-41-23).
The new solidification system is expected to reduce volumes of waste. A more efficient compactor has reduced the volume of dry waste about 35%. The licensee plans to use strippable paint.in the reactor cavity for future refueling. outages which should reduce the volume of decontamination liquids and solids which require disposal.
It should be noted that allotments imposed on the amount of waste that-will be accepted at burial sites such as Barnwell, SC, give the r
licensee incentive to reduce volumes of waste. As an indicator of the licensee's. ef. forts ' to r'ed'uce' waste volumes, signs ha've been posted throughout the plant admonishing personnel not to generate unnecessary
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wastes.
Records and graphs maintained by the waste manager indicate that the volume reduction program has been effective in that a definite dcwnward trend is reflected. The inspector stated that during tours of
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the plant, it was observed that workers were still taking cardboard ooxes, packing material and other disposal material into contaminated a eas.
Radioactive wastes reduction _should be stressed during the raiiation protection orientation training (348/80-41-24).
Licensee
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procedures ' address.the requirements of 10.CFR 71 -for' packaging and
. tran sportati on. of 'wa stes. The *litensee has depended. primarily on con-
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tractors for certified. shipping containers. Licensee records contained
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. certificate 0 for the contractor shipping containers.and decriptions of.
the contractors QA program for shipping containers. A problem has been
. experienced in maintaining spent resin flow through piping with exces-
.sive bends.and. steep slopes. The present location. of the dry waste i
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compactor is undesirable' from the s'tandcoint of degree of isolation.
necessary to reduce the potential of exposure to other personnel in the vici nity The-exhaust from the compactor is filtered; however, it
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exits directly to the room which is occupied by other personnel not associated with the compacting operations.
Licensee personnel indi-cated that the compactor may be moved to a new waste handling and storage f acility on which construction is soon to begin. The inspector.
stated that prompt action should be taken to enclose the compactor (e.g.,
tent,- metal building, etc.) (348/30-41-25).
Wastes.have apparently been shipped in.a timely manner as evidenced by good house-keeping in the midst of an outage. Discussions were held with licensee
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personnel concerning the caution to be exercised in not accumulating excess wastes in the new storage facility when it becomes available.
Procedures for calibration of particulate, iodine, noble gas and area
monitor detectors were reviewed.
There are over 40 systems used for monitoring area, process and effluent releases. Most of these systems were identified in-plant and their operating conditions verified. Two portable Eberline SPING-4 systems were in plant, but these units had just been received from the manufacturer and had not been made opera-tional.
Routine calibrations are scheduled from monthly.to 18 month intervals, depending on the type monitor.
Setpoints have been justified and documented in FNP-1-RCP-252, May 6, 1980, Rev. 3.
The Instrument and Control (I&C) Group has the responsibility for routine instrument calibration, but the radiation protection section has responsibility for actual source calibrations. This working arrangement is beneficial because skills not usually found in the I&C group can be supplemented by health physics personnel.
b The written procedures are not useful for OJT. This problem has been identified by the HP technicians. The licensee should develop docu-ments that can be used t'o train personriel in the proper calibration of the monitors (348/80-41-26).
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Area Radiation' monitors are set by positioning a Cs-137 source at a distance from the detector to produce the desired exposure rate. Two point calibrations are generally used.
Detectors containing G.M.
detectors are required to have H.V. plateaus set curing initial cali-
- bration of the G.M. detector with no more than 15's slopes. Particulate detectors are also calibrated with Cs-137 sources, but fixed geometry
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fs maintained and there is a.. method for calculated source decay in the
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procedures.
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-.The. Westinghouse fixed moriitors'suse Sr-90/Y-90 secondary source cali-brators, commonly called " cap" sources.
These sources fit over the G.M. detectors-that are pulled from the shield in the fixed monitor.
The. secondary cal.ibration; source.is related directly to a " typical" calibration'of th'e monitor to gaseous levels of Xe-133 and Kr-SS.
Other monitors have been calibrated with I-129, Sr-90/Y-90, Tc-99 and C l -3 6 '. The ' sources and procedures appear appropriate for the rescec-tive monitors and detectors. Iodine monitors are generally calibrated
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with " mock iodine" sources (a combination of Cs-137 and Ba-133 that simulates the I-133 energy).
The G.M. tubes used for noble gas monitoring are open to the air stream (by manufacturer design). Because of this design, the beta particles can be detected. It has been found that G.M. tube wall thickness vary from manufacturer to manufacturer. Therefore, beta secondary standards are not appropriate for every type G.M. tube. The licensee has identi-fied this problem and adjusted the calibration correction factors for
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" cap" sources according to G.M. tube manufacturer.
Several maintenance problems.were identified with fixed monitors.
Because of extreme heating, air pump failures occur in some fixed monitors every six months or so.
Failure of the' system necessitates recalibration of the air flow system.
In units with movable filter paper, modifications of systems were necessary when the original type filter paper was no longer available. Strip chart recorders are also frequent repair problems because of jamming or poor feeding of paper.
This latter problem was noted by the inspector in a control room air monitor readout.
Although every fixed monitor did not have a " primary calibration" as required in ANSI N13.10-1974, typical calibrations of Westinghouse monitors were available and effort was being made to properly relate calibrations to secondary standards.
No calibration procedures had been established for newly procured SPING-4 monitors.
e.
Summary: Based on the above findings, this portion of the licensee's program appears to be acceptable, but the followup matters should be
, considered for. improvement.cf.the program:
(1) waste reduction training for plant personnel; (2)
isolation of the dry waste compactor; and (3) development of documents to train I&C and HP personnel in the calibration of fixed radiation monitors.
10. ALARA Program 10 CFR 20.1c states that persons engaged in activities under licenses issued
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l by the NRC should make every reasonab?e effort to maintain radiation expo-sure as low as reasonably-achievable. (ALARA). The recommended elements of
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an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational. Radiation Exposure at Nuclear Power Stations i
will be ALARA, and Regulatory Guice 8.10, Operating Philosophy for Main-j taining Occupational Radiation Exposures ALARA.
The Ticensee 'has a ' written policy and commitment to an AURA program. A section supervisor has been assigned the responsibility for the ALARA program anc he reports directly to tne C&HP supervisor. The program is the i
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sole job responsibility of the ALARA supervisor. Written procedures are available to imolement the program. ALARA Problem and Evaluation Reports, l
by which any plant personnel can report an identified problem in the ALARA program, are routinely'used. The ALARA supervisor reviews design changes, equipment changes and performance of specific work activities to assure that ALARA concepts are considered. This was verified by review of-records which revealed input by the ALARA supervisor for the new demineralizer system, solidification system and waste storage f acility.
The ALARA supervisor
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closely coordinates his activities with plant Health Physics. Several items observed by the inspectors during plant tours were enumerated to the ALARA sucervisor such as: -(1) higher than normal general radiation background in the area of the. Hydrogen recombiner control panel; (2) potential for un-necessary exposure to personnel in'the.new compactor and. drum storage areas; (3) temporary sampling facilities for waste evaporator distillate; and (4)
outside storage of plywood boxes containing waste. The ALARA supervisor was aware of all the items and indicated corrective actions were in progress or planned.
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Summary: Sased on the finding above, this portf on.of the licensee's program appears to be acceptable.
11.
Facilities and Equipment a.
Facilities The health physics foremanf s office is located adjacent to the entrance to the radiation control area. Although this space is conveniently located, it is small and inadequate for the in plant health physics staff. Additional work space is needed for the health physics foremen.
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The counting' room is loca'ted in the auxiliary buiiuing. High airborne radioactiNity experienced during an accident probably will render this area unusable. However, the licensee has considered this possibility
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and is planning to locate-an alternate counting facility at the training center now under construction.
b.
Equipment
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Calibrations and control of fixed and portab.le health physics instru-
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mentation is.de' scribed ;i.n F&rley Nuclear Plant Procedure, FNP-0-RCP-201, July-11, '1978, Revi sion 3.
This procedure calls for identi-
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fication, inventory, maintenance, calibration and record keeping of f
portable. instruments.w Although this procedure is generally adequate, the inspector recommended that it be updated to include record keeping
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information found in ANSI N323-1978, Radiation Protection Instrumenta-t tion Test and Calibration.
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At the time of the inspection, an adequate number of protable survey instruments was available. Unit No. 2 was nearing fuel loading status
and purchase orders had been placed to essentially double the number of i
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routinely used instruments.
s Instrument. calibration procedures were reviewed by the inspector. Most of these procedures were written in 1978 or before.
There are no.
references to the ANSI N323-1978 standard. In FNP-0-RCP-207 and -208,
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G.M. survey meters are referred to as " dose rate" instruments. Other procedures refer to " gamma field" but do not specify the isotope (i.e.,
Cs-137).
Instrument responses are required to be "within 10%", but
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factors.affecting accuracy (i.e., temperature, pressure, humidity, i
geometry, scatter, positioning and NBS intercomparisons) are generally.
not considered.
The procedures allew the use of "off-site" calibra-i tion, but no guidance is proviced as to when it is necessary for
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off-site calibration. The inspector recommended that the procedures be
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revised to meet current standards (348/80-41-27).
Simple instrument maintenance is accomplished by the health physics e
section. Routinely used instruments are repaired by the Farley instru-i ment group. Inventories of spare parts are kept for. these instruments.
Other instruments, such as teletectors, are sent to the manufacturers
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for repair. Instrument repair has not been a problem as evidenced by the fact that over 85% of the instruments were functional'at the time of the inspection.
Instruments are normally response checked on a daily basis.
Gamma check sources. are maintained inside the instrument storage cabinet.
Other check sources are maintained in the calibration laboratory.
An Eberline Model 1000B Mult'iple SouFce' Gamma Calibrator"had recently
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been purchased for instrument calibrations. Although this instrument does not conform to all the requirements. set-forth in ANSI N323-1978,
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it is especially useful in reducing personnel exposure and in verifying
the " precision" of the instrument calibration. The inspector cautioned
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that the energy distribution within the calibrator should be known and l
that survey instruments with broad energy responses may be difficult to
- accurately calibrate in this device. Intercomparison with laboratories conforming to AFSI N323-1978 is recommended.
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- The teletector survey instrument h'ad not been calibrated on the high
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range scales. The inspector recommended that a calibration procedure
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-,for the.telitector be. implemented to determine-the relative response on
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high ranges. Other facilities.have typically reported underresponses l
of 50% on high range scales of the teletectors.
NBStracea'b'ility'isestab"lisOdforgammasources'bycondenserR-meter
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j calibrations at the manuf acturer's regional calibration laboratory. A
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uranium slab source was available for. beta source calibration. Neutron
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J calibrations are established with an 8.5 C1' PuSe : source.
Standard'
l Pu-239 alpha sources are available for use.
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The R02/2As were' routinely used for beta radiation surveys..A correc-
tion factor of 4 had been established for con;:ct beta measurements.
Air _ sampler calibration flow rates had been established-by. manometr.ic methods and magnehelic gauges.
These methods are described in the =
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appropriate procedures.
A' calibration laboratory.was built in = the auxiliary building.
This
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facility is convenient and allowed ample stcrage for broken instruments and for' record keeping ~.
In' general,,. instrument calibration training was. regimented.. Most of
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the technical knowledge of instrument calibration was' supplied by the HP foreman.. The inspector recommended ' additional technical training
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for Lead Technicians involved in and responsible for instrument cali-brations.
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Summary: Based on the above findings, this portion of the licensee's
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program appears to be acceptable, but consideration should be given to
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upgrading instrument calibration procedures.
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