IR 05000382/1982004
| ML20053C300 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/17/1982 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20053C295 | List: |
| References | |
| 50-382-82-04, 50-382-82-4, NUDOCS 8206010644 | |
| Download: ML20053C300 (55) | |
Text
{{#Wiki_filter:_ _______________ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ e , U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Report: 50-382/82-04 Docket: 50-382 Construction Permit No. CPPR-103 Licensee: Louisiana Power and Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Facility: Waterford-3 Taft, Louisiana Inspection Conducted: March 1-5, 1982 6//7/[[ Inspector: I h
H. Chaney, Radiation S cialist Dste '
O //lM 8//7/ 2-Approved:
BlaineMurray, Chief,pcilitiesRadiationProtection (Tate ' , Section Inspection Summary Inspection on March 1-5, 1982 (Report 50-382/82-04) Ar2as Inspected: Routine, unannounced initial inspection of the licensee's Radiation Protection Program including: organ nation; staffing; qualifications; training; exposure control; facilities and equipment; instrumentation; ALARA program; and procedures. The inspection involved 68 onsite hours by one NRC inspector and the Chief, Facilities Radiation Protection Section.
Results: No violations or deviations were identified.
Eighteen open items are discussed in paragraph 4.
82060lOGV/
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' DETAILS f 1.
Persons Contacted ,
Louisiana Power and Light Company (LP&L)
- D. B. Lester, Plant Manager
- S. A. Alleman, Assistant Plant Manager r
- C. R. Bcoth, Utility Chemistry Engineer
- T. F. Gerrets, QA Manager
- C. Groonie, Environmental Licensing Engineer J. Guillot, Utility Engineer Nuclear, QA
- D. M. Hall, Associate Engineer, Health Physics Group
,
- R. W. Kenning, Health Physics Superintendent, Radiation Protection
' Manager-RPM
D. A. Landeche, Technical Specialist ' '
- J. Lewis, Radiation Control Engineer (Corporate)
- J. R. McGaha, Technical Support Superintendent
! B. Morgan, Operations QA Supervisor l
- W. M. Morgyn, Operations QA Engineer
' W. N. Perry, Head, Chemistry Department
- L. R. Simon, Engineering Technician Others
. R. H. Loe, Health Physics Technician, Nuclear Support Service; (NSS) C. J. Toth, Training Department Consultant, NSS I. R. Seybold, Health Physics Technician, NSS
- G. L. Constable, NRC Senior Resident Inspector i
- Denote those present during the exit interview.
P The inspectors also interviewed several other Waterford-3 (WF-3) station personnel during the inspection.
2.
Scope of Inspection This inspection covered an initial review of the licensee's Radiation Protection Program.
3.
Licensee Action on Previous Inspection Findings ' ! l (Closed) Open Item (50-382/81-16/01): Radiation Protection Manager (RPM) ' Reportina Chain-of-Command - This item was identified in Inspection Report 5s-382/81-16 and involved the location of RPM within the licensee's organizational structure.
The reporting sequence for the RPM -' has not changed from that discussed in Inspection Report 50-382/81-16.
This item is considered closed; however, a similar open item is identified in this report.
See Section 5.b of this report.
. y _ _ , , _. - -, - - - .-,
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' . (Closed) Open Item (50-382/81-16/02): Qualifications of the Radiation Manager - This item was identified in Inspection Report 50-382/81-16 and involved the qualifications of the designated RPM in order to satisfy the recommendations of Regulatory Guide 1.8.
This item is considered closed.
See Section 6 of this report.
(0 pen) Open Item (50-382/81-16/04): Unshielded Reactor Coolant Sample Lines - This item was identified in Inspection Report 50-382/81-16 and involved the location of unshielded reactor coolant sample lines near the proposed health physics field office.
The licensee is currently evaluating this problem.
This item remains open pending further review.
See Section 14 of this report.
(Closed) Open Item (50-382/81-16/06): Space Allocation for Laundry and Respiratory Protection Equipment - This item was identified in Inspection Report 50-382/81-16 and involved possible insufficient space allocation for the laundry facility and respiratory protection program.
This item is considered closed.
See Section 14 of this report.
4.
Open and Unresolved Items Identified During This Inspection (0 pen) Open Item (50-382/82-04/01): Corporate Radiation Protection Organization - The licensee had not: completed staffing of functional areas; developed position qualifications and job descriptions; or developed operational procedures for functional areas. See Section 5.a for additional details.
(0 pen) Open Item (50-382/82-04/02): Station Health Physics Organization - The licensee had'not: established an RPM reporting chain-of-command as recommended in Regulatory Guide 8.8; completed Health Physics Group (HP Group) staffing; developed job descriptions; or completed HP Group operating procedures.
See Section 5.b for additional details.
(0 pen) Open Item (50-382/82-04/03): Radiation Protection Organization Qualifications - The licensee had not established instructions for determining acceptable training and experience for personnel assignment to the radiation protection organization.
See Section 6 for additional details.
(0 pen) Open Item (50-382/82-04/04): Radiation Protection Training Program - The licensee had not: established a training program for radiation protection; completed training department staffing; or completed program procedures.
See Section 7 for additional detail *
, (0 pen) Open Item (50-382/82-04/05): Radiation Exposure Control Program - The licensee had not established an external radiation exposure monitoring program that would provide for: beta, gamma, and neutron . exposure monitoring; implementation of a QA/QC program; or necessary reports ' on personnel exposure as required by 10 CFR 19.13. See Section 8.a for additional details.
(0 pen) Open Item (50-382/82-04/06): Internal Radiation Exposure Control Program - The licensee had not established a bioassay program that would ensure internal radiation exposure is accurately measured and documented.
f See Section 8.b(1) for additional details.
(0 pen) Open Item (50-382/82-04/07): Respiratory Protection Program - I The licensee had not established a respiratory protection program as required by 10 CFR 20.103.
See Section 8.b.(2) for additional details.
(0 pen) Open Item (50-382/82-04/08): Radiological Surveys - The licensee had not established a comprehensive survey program.
See Section 8.c for additional details.
(0 pen) Open Item (50-382/82-04/09): Radiation Work Permit (RWP) Program - The licensee had not established an RWP program as committed to in the FSAR, Section 12.5.3.4.
See Section 8.d for additional details.
(0 pen) Open Item (50-382/82-04/10): ALARA Program - The licensee had not established an ALARA program as recommended by Regulatory Guide 8.8.
See Section 9 for additional details.
l (0 pen) Open Item (50-382/82-04/11): Radiological Posting - The licensee had not completed all procedures to establish a proper radiological posting program.
See Section 10 for additional details.
(0 pen) Open Item (50-382/82-04/12): Notification and Reports - The licensee had not established a program for notifications and reports as recommended in Regulatory Guides 1.16 and 10.1 and as required by 10 CFR Part 19 and 10 CFR Part 20.
See Section 11 for additional details.
< (0 pen) Open Item (50-382/82-04/13): Health Physics Protective Equipment and Supplies - The licensee had not completed stocking or establishing an inventory program for station protective equipment and supplies.
See - Section 12 for additional details.
. I ! (0 pen) Open Item (50-382/82-04/14): Radiation Protection Instrumentation - The licensee had not completed procurement of all instrumentation; developed all necessary operational and calibration procedures; or established an instrument response check program.
See Section 13 for additional details.
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- !
..
, - - _ _ _ _ _ _ _-_ .________ _ ______ _ _ _ _ _ ___ _ .. .
. (0 pen) Open Item (50-382/82-04/15): Facilities - The facilities associated with the HP Group had not been completed.
See Section 14 for more details.
(0 pen) Open Item (50-382/82-04/16): Audits and Reviews - The licensee had not established an audit and review program for the station HP Group activities.
See Section 15 for additional details.
(0 pen) Open Item (50-382/82-04/17): Reactor Sta tup Surveys - The licenset had not completed the radiological survey procedure for initial -eactor power ascension or a program to verify plant airflow characteristics.
See Section 16 for additional details.
(0 pen) Open Item (50-382/82-04/18): Procedurer - The licensee had not completed all procedures necessary to implement 6 proper health physics program.
See Section 17 for additional details.
5.
Radiation Protection Organization The inspectors examined the licensee's corporate and onsite organizations regarding radiation protection activities to determine compliance with the Final Safety Analysis Report (FSAR) commitments, recommendations of Regulatory Guide 8.8, and NUREG-0731 and NUREG-0761.
Documents Reviewed FSAR Chapter 13, " Organizational Structure of Applicant."
. DL-81-164-7, Job Description for Radiation Control Engineer-Nuclear . (Draft), dated November 30, 1981.
D L-81-164-28, Job Description for Radiation Control Utility . Engineer-Nuclear (Draf t), dated November 30, 1981.
D L-81-164-44, Job Description for Radiation Control Engineering . Technician-Nuclear (Draft), dated November 30, 1981.
l Job Description, " Health Physics Superintendent" (Draft).
. Job Description, " Health Physics Utility Engineer" (Draft).
. Job Description, " Dosimetry Supervisor" (Draft).
. l l I .. ... . _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _-_____ __ _ a
. Job Description, " Health Physics Training Coordinator" (Draft).
. Job Description, " Health Physics Supervisor" (Draft).
. Job Description, "ALARA Coordinator" (Draf t).
. Job Description, " Health Physics Technical Specialist" (Draft).
. Job Description, " Senior Health Physics Technician" (Draft).
. Job Description, " Junior Health Physics Technician 3" (Draft).
. Job Description, " Junior Health Physics Technician 2" (Draft).
. Job Description, " Junior Health Physics Technician 1" (Draft).
. a.
Corporate Radiation Control Organization The following chart shows the LP&L corporate radiation control organization for Waterford-3.
Nuclear Operations V.P. Nuclear Ops.
Nuclear Proj. Support Proj. Support Manager Nuclear l Technical Services Eng. Supv. Nuclear Radiation Control Engineer-Nuclear Exposure Control Laboratory Service Group Group i ~ l Utility Eng. Nuclear Utility Eng. Nuclear Eng. Tech. Nuclear Eng. Tech. Nuclear The Radiation Control Engineer has tentatively assigned the following responsibilities to the Exposure Control and Laboratory Service groups: Exposure Control Group As Low As Reasonably Achievable (ALARA) program . .. .. . _ _ _
. Design reviews Radioactive waste Respiratory protection Exposure control Emergency Plan Contracts administration Equipment evaluations Vendor files Procedure review Appraisals and audits Special Projects Institute of Nuclear Power Operations (INPO) and American Nuclear Insurers (ANI) criteria NRC exposure reports NRC monthly operating reports NRC bulletin, circular, and notice review Other plant information Review and prepare Licensee Event Reports (LERs) Maintain Health Physics Manual Laboratory Service Group External and internal dosimetry program Radiological effluent technical specifications Environmental program Counting room (site) Counting room (corporate office) Byproduct licenses Procedure reviews Appraisals and audits Training interface Special Projects NRC effluent reports Equipment evaluations Regulations (review and comment) Licensing activities support NRC bulletin, circular, and notice review Other plant information Review and prepare LERs l The corporate radiation control organization is still in the development
stage and key subgroup positions have not been filled.
The Radiation l Control Engineer was actively recruiting to fill remaining positions with qualified personnel. The Radiation Control Engineer views his position as supportive to the station's HP Group.
Also, the Radiation Control Engineer appears to meet Regulatory Guide 1.8 qualifications for an RPM.
The inspectors are concerned that the corporate radiation control organization program regarding staffing, job descriptions, assignment of responsibilities and implementation of procedures governing functional areas of responsibilities are only in the planning stage with possible issuance of the operating license within the next 9 months.
- -. - - _ - _. - - - -- .-
__
. This item is open (82-04/01) pending: Completion of corporate Exposure Control Group and Laboratory . Services Group staffing.
Development of position qualifications and job descriptions.
. Development of procedures governing activities within assigned . areas of responsibility.
b.
Onsite Radiation Protection Organization - HP Group . The following chart shows the existing station management organization as it pertains to HP Group activities.
Plant Manager Nuclear i Asst. Plant Manager Nuclear I
Health Physics Superintendent Technical Support Nuclear Superintendent i HP Group I L I . Nuclear Radwaste ' Chemistry Plant Engineering ' ' Engineering Department Department Department Department Staffing Staffing Staffing of 71 , Staffing of 5 of 5 of 7
- Radiation Protection Manager
' i The following chart shows the current onsite HP Group organization.
, , I ,
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--._ - N a ,
Health Physics Superintendent-Nuclear l s l Utility Eng. Nuclear l l
l HP Supv. Nuclear l l HP Supv. Nuclear l lAssc. Eng. I/II Nuc.l t Tech. Spec. Nuc.
Tech. Spec. Nuc.
l Eng. Technician-Nuc.
Technician-Nuclear Technician-Nuclear The following chart shows the proposed organization for the onsite HP Group.
Implementation is planned for June 1, 1982.
,
Health Physics ! Superintendent HP Administration HP Operations HP Operations Utility Engineer __HP Supervisor HP Supervisor ' I Surveys Office r- - - - -- j - - T - - -- - - - I Count Room Control Point Resp. Prot. Prog.
Job Coverage i I I Inventory & Supply I I Il l Trainina ALARA Dosimetry AE/ET* AE/ET AE/ET I I l l 3 Rad. Worker Training I ALARA I TLD's I alib.
IResp. Prot. Training I Procedure Writing C
i iHP Tech. Training Special Projects IWhole Body I I Counting i l 3 Records l - ! I I I I l ' i
i i i i . ' l 2 technicians l l 2 technicians I l 3 technicians l l 6 techniciansll7 techniciansI c , ! OAE/ET - Associate Engineer / Engineering Technician l l + - - .- -- -. . _, .. .. -. - - . -. - . . . -
_ _ _ - _ _ _ , . ,
. The inspectors are concerned regarding the present onsite management organization in regard to HP Group activities.
The management organizational chart has the HP Superintendent (RPM) reporting through the Assistant Plant Manager to the Plant Manager.
This item had previously been reported by NRC Inspection Report 50-382/81-16.
NUREG-0761, " Radiation Protection Plans for Nuclear Power Reactor Licensees," provides acceptance criteria for determining adequacy of plant radiation protection organization and function plans, in that it recommends: "The organizational structure should show clearly that the Radiation Protection Manager (RPM) has access to the Plant Manager in matters of radiation protection and is independent of operating pressures." Similar recommendations are contained in NUREG-0731, " Guidelines for Utility Management Structure and Technical Resources," and Regulatory Guide 8.8, Section C.lb.(3).
The management organizational chart indicates that the Assistant Plant Manager has many areas of responsibility that may preclude adequate day-to-day participation in the radiation protection program. The licensee stated that, even though a documented reporting path to the Plant Manager for the RPM did not exist, the RPM would have access to the Plant Manager to discuss radiological matters.
Also, the licensee's organizational structure did not show that the RPM had access to corporate management concerning radiological matters not resolved at the plant level.
The inspectors are also concerned that the RPM has not filled existing vacancies for the positions of Utility Engineer-Nuclear (designated RPM during extended absences of the HP Superintendent) or the two HP technician supervisors.
NUREG-0761 recommends that there should be a qualified (Regulatory Guide 1.8) substitute for the RPM available to the site when the RPM is not available for extended periods due to illness, travel, or vacation.
Also, the inspectors determined that job descriptions, qualification requirements, or implementing procedures for functional area assignment have not been completed.
The inspectors further noted that no provisions have been established for evaluating qualifications of contractor HP personnel.
The inspectors noted that only the HP Superintendent's proposed job description provides authority and responsibility for stopping work that is being accomplished in an unsafe radiological manner.
NUREG-0761 recommends that functional job descriptions should clearly specify that: " Senior radiation protection technicians have the responsibility and authority to stop work or order an area l l - - _ _ _ _ _ _ _ _ _
. evacuated (in accordance with approved procedures) when, in their judgement, the radialogical conditions warrant such an action and such actions are consistent with plant safety.
Furthermore, it should be clearly understood by all station personnel that cnly radiation protection management, the Plant Manager or their designated representatives on backshifts, can overrule such a stop-work order."
The number of HP personnel indicated on the staffing charts appears to be sufficient to meet staffing requirements for routine operation.
The licensee is currently seeking qualified personnel to fill the vacant HP Group supervisory positions.
This item is considered open (82-04/02) pending: Licensee evaluation of the reporting sequence for the RPM to onsite . , and corporate management.
Staffing of the HP Group.
. Implementation of HP Group job / position descriptions and ' . operating procedures for key functional area assignments.
6.
Radiation Protection Organization Qualification The inspectors reviewed the qualifications of the radiation protection personnel including corporate, onsite, and contractors to determine agreement with commitments in the FSAR, the recommendations of Regulatory Guide 1.8, ANSI N18.1, and NUREG-0731.
Documents Reviewed Health Physics Group personnel training and experience resumes.
. Corporate radiation control organization personnel training and . experience resumes.
NUREG-0787, " Safety Evaluation Report - Waterford Unit 3 - July 1981."
. , ANSI N18.1-1971, " Standard for Selection and Training Personnel for . l Nuclear Power Plants."
> Corporate I The inspectors determined that the corporate Radiation Control Engineer (corporate Health Physicist) met the FSAR commitments, which follow the recommendations of NUREG-0731.
The licensee has not filled all subgroup
i , i - _. - _ . -. - . -- -
- positions in the corporate radiation control organization (see open item 82-04/01), and had not established instructions providing definitive guidance on evaluation of personnel training and experience for determination of qualification to at least ANSI N18.1
recommendations.
The Radiation Control Engineer had drafted basic qualification guidelines for positions within his organization.
L Onsite i Table 1 shows the education and experience background information on paranel currently assigned to the HP Group. The licensee has
c '.cted to, in the FSAR, the utilization of the qualification requirements recommended in ANSI /ANS 3.1-1978 (not currently adopted by the NRC), which are more stringent than those contained in (and endorsed by the NRC) ANSI N18.1-1971.
The inspectors noted that 5 out of the 13 HP technicians listed in Table 1 do not appear to meet the experience recommendations for health physics technicians as contained in Section 5.4.2 of ANSI N18.1-1971.
The inspectors determined that the licensee had not implemented procedures that would provide definitive guidance for the determination of acceptable health physics experience for station or contractor personnel.
This item is considered open (82-04/3) pending the establishment of qualification criteria for both corporate and onsite radiation protection personnel.
Inspection Report 50-382/82-16 identified an open item (81-16/02) regarding the qualifications of the proposed Radiation Protection . Manager in order to satisfy the recommendations of Regulatory Guide 1.8 (Revision 1-R), " Personnel Selection and Training." This matter was discussed in Section 12.5.1 of NUREG-0787, in which the Office of Nuclear Reactor Regulation (NRR) found the Health Physics Superintendent . to be a qualified RPM.
The inspectors agree with NRR's position on this ! matter.
Item (81-16/02) is considered closed.
L , __ _
- . TABLE I ONSITE HEALTH PHYSICS GROUP PERSONNEL QUALIFICATIONS N:me Title Degree Total Total * Commerical Resume Above High Nuclear Exp.
Commerical Nuclear Avail.
School Nuc. Exp.
Operating Plant Exper.
(yr's mo's) (yr's mo's) (yr's mo's) R.W. Kenning HP Supintendent MS-HP 6 yrs. O mo.
6 yr. O mo.
2 yr. O mo.
yes L. R. Simon Engineering Tech. BS-Ind. Tech.
6 yr. O mo.
3 yr.10 mo. 0 yr. 3 mo.
yes D. H. Espeman Associate Engr. I MS-HP 2 yr. 9 mo.
2 yr. 9 mo.
1 yr. 2 mo.
yes D. M. Hall Associate Engr. I MS-HP 3 yr. 10 mo.
3 yr. 10 mo. 3 yr. 4 mo.
yes D. L. Hoel Tech. Specialist 9 yr. 11 mo.
3 yr. 11 mo. 0 yr. 4 mo.
yes D. B. Stevens HP Technician AS (2 yr.)
5 yr. 4 mo.
3 yr. 2 mo.
1 yr. 2 mo.
yes D. A. Landeche HP Technician 8 yr. 4 mo.
2 yr. 4 mo.
0 yr. 2 mo.
yes N. I. Huber HP Technician 19 yr. 3 mo.
2 yr. 3 mo.
0 yr. 5 mo.
yes M. W. Van HP Technician 3 yr. 5 mo.
3 yr. 5 mo.
1 yr. 6 mo.
yes Derhorst R. T. Meschler HP Technician AS (2 yr.)
6 yr. 2 mo.
5 yr. 5 mo.
4 yr. 3 mo.
yes J. Bickham HP Technician 7 yr. 4 mo.
5 yr. 2 mo.
4 yr. 8 mo.
yes J. H. Herring HP Technician BS-Biology 3 yr. O mo.
3 yr. O mo.
2 yr. 6 mo.
yes R. C. McLendon HP Technician BS-Biology 2 yr. 10 mo.
2 yr. 5 mo.
2 yr. 5 mo.
yes P. M. Kelly HP Ttchnician 6 yr. 2 mo.
0 yr. 2 mo.
0 yr. O mo.
yes J. R. Croxton HP Technician BS Engr. Physics 5 yr. 4 mo.
5 yr. 4 mo.
4 yr. 4 mo.
yes
- I. R. Seybold HP Technician 14 yr. 7 mo.
7 yr. 7 mo.
7 yr. 5 mo.
yes
- R. H. Loe HP Technician AS (2 yr.)
14 yr. 5 mo.
2 yr. 5 mo.
2 yr. 3 mo.
yes
- Experience associated with design, construction, and preoperational activities of commercial nuclear plants.
^^ Contracted HP Personnel - NSS l
. 7.
Radiation Protection Training Program The inspectors reviewed the licensee's radiological training program to determine compliance with FSAR commitments, 10 CFR 19.12 requirements, and the recommendations of ANSI N18.1-1971, NUREG-0761, and Regulatory Guides 8.13, 8.27, and 8.29.
Documents Reviewed PMD-TR-002, " Program Description for General Employee Training (GET)" ! . (Draft), Revision 0, January 15, 1982.
PMD-TR-021, " Program Description for Health Physics Training" (Draft), . Revision 0, February 2, 1982.
PMD-TR-010, " Nuclear Operations Department Training" (Draft), Revision 0, . February 22, 1982.
PMD-TR-009, " Program Description for Nuclear Training Group . Organization" (Draft), Revision 0, January 12, 1982.
. Lesson Plan Course I, " Radiological Health and Safety" (Draft), not . dated.
. t i Lesson Plan Course II, " Radiation Worker" (Draft), not dated.
l . Lesson Plan Course III, " Respiratory Protection" (Draft), not dated.
l . ! At the time of this inspection, the Nuclear Training Group was being
reorganized.
As such, the roles and responsibilities for the corporate t Nuclear Training Group and the onsite HP Group concerning training [ activities had not been established.
The inspectors discussed the proposed training programs for General [ Employee Training (GET) with the Training Group Manager (NSS-Consultant) and instructors.
The inspectors noted that initial GET training (courses I & II) had been provided to certain station personnel; even though, the subject GET training program and lesson plans had not been formally approved.
Due to the absence of official program objectives
and lesson plans, the inspectors did not investigate GET further.
The inspectors noted that there was no formal guidance on qualification and certification of training instructors.
- ! The onsite HP Group had developed a proposed HP personnel training program that appears to meet the recommendations of NUREG-0761, with the exceptions > t - - -
- _ . _ _ _ _ __ __ _ ___ _.
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, that it did not provide: guidelines on verification of experience or training of station and contractor personnel prior to job assignment or waiver of training requirements; use of oral examinations in conjunction with comprehensive written examinations
i to verify competency of technicians; or appropriate requalification standards for senior HP technicians and technical specialists.
'
i The RPM indicated that initial HP technician radiological control-
training was accomplished, for some personnel, by having them attend
offsite health physics training courses presented by another utility.
- The licensee indicated that this type of training may not be available in
'
the future to all HP technicians. The licensee has not completed '
procedures that. address retraining requirements for technicians, - supervisors, or staff technical personnel. Draft procedures on
i radiological training do not appear to satisfy NUREG-0701 , recommendations for providing specialized training for personnel
' directing operations, such as ALARA, respiratory protection, or
- .
r .i external and internal dosimetry.
i The inspectors noted that the licensee did not have a technical l library for members of the HP Department and that-there was no program
i established to ensure the industry technical materials and standards ' were routed through the HP Group.
, This item-is considered open (82-04/04) pending implementation of an
acceptable HP Group training program.
, l-8.
Personnel Radiation Exposure Control [ a.
External i ! ! . l l ! The inspectors reviewed the licensee's external dose control program ! to determine compliance with: FSAR commitments; the requirements of ' 10 CFR 19.13, 10 CFR 20.101a, 10 CFR 20.10lb, 10 CFR 20.102, 10 CFR
20.202a,10 CFR 20.104a, and 10 CFR 20.401a; and the recomendations
, i contained in Regulatory Guides '.8.4, 8.8, 8.14, ANSI N13.2-1969, 1-N13.6-1972, N13.11, N319-1976, and NUREG-0761.
l Documents Reviewed FSAR, Sections. 12.5.2.2.3'and 12.5.3 7.
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15 - , Policy, " Radiation Protection Policy," Louisiana Power and Light . (LP&L) Company, not dated, signed by Senior Vice President-Operations.
Policy, " Female Radiation Exposure Policy" (Draft), no date.
. Procedure HP-1-100, " Administrative Procedure - Health Physics . Manual" (Draft-2), Revision 0, not dated.
Procedure HP-1-109, " Administrative Procedure - External Radiation . Exposure Control and Dosimetry Issuance," Revision 0, November 18, 1981.
Procedure HP-1-110, " Administrative Procedure - Radiation Work . Permits" (Draft), Revision 0, January 18, 1982.
Procedure HP-2-102, " Health Physics Procedure - Use of Self Reading Pocket Dosimeters," Revision 1, September 10, 1981.
Procedure HP-2-106, " Technical Procedure - Noble Gas Equivalent . Calculation," Revision 0, March 8, 1982.
The licensee's external exposure control program has not been fully i established.
The inspectors noted that the licensee intends to use an automated computer-based TLD system for personnel dosimetry.
Based on a review of existing procedures, the inspectors determined that a program had not been established to accurately monitor personnel skin dose due to beta radiation when working on major pieces of highly radioactive reactor plant equipment or areas with high levels of loose surface contamination.
The inspectors also noted that procedures did not adequately address the use of multiple position personnel dosimetry (in nonuniform radiation fields), or provide for acceptable tracking of extremity exposure between monthly TLD processing to ensure the exposure limits of 10 CFR 20.101.a and 10 CFR 20.202.a(1) are not exceeded.
The licensee i - - - -. - - .
_.
. .. .... - . . .
' . has not established a personnel neutron exposure monitoring program t that satisfies the recommendations contained in Regulr. tory Guide 8.14 and ANSI N319-1976.
The licensee has established administrative procedures, which are ' more restrictive than 10 CFR 20.101 limits, to control personnel exposures.
Approval by station management is necessary prior to exceeding administrative limits.
The licensee's exposure control , . procedures appear to satisfy the female radiation exposure
recommendations contained in Regulatory Guide 8.13.
The inspectors i determined that the exposure record system does not satisfy the requirements of 10 CFR 19.13 in that terminated employees are not i provided with information relative to bioassays performed while l employed at the station.
' - The licensee has not established procedures far-operation, ! calibration, or maintenance of personnel exposure records for the TLD system.
i This item is considered open (82-04/05) pending: , Development and implementation of a personnel exposure (beta, i . gamma, and neutron) monitoring program.
t i Completion of procedures that will assure: . Skin exposure due to low energy gamma and beta radiation, i . is adequately monitored and documented.
The use of multiple position personnel monitoring.
. t Implementation of 10 CFR 19.13.
' . An adequate QA/QC program for the expcsure control and records . program.
b.
Internal Exposure Control ! I The inspectors examined the licensee's internal exposure program to determine compliance with: FSAR commitments; the requirements of I c - r I , l!- - - - -.. - . -. - - - -, . - _ -
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. , i - , , ! 10 CFR 20.103, 10 CFR 20.201, and 10 CFR 20.401; and the , ' recommendations of Regulatory Guides 8.9, 8.15, 8.21, 8.25, 8.27; j ANSI N343-1978; and NUREG-0041 and 0761.
, ,, ' Documents Reviewed ' FSAR Sections 12.5.1.2, 12.5.3.7.2, and 12.5.3.8.
. Procedure H-1-100, " Administrative Procedure - Health Physics t .
Manual" (Draf t-2),' Revision 0, not dated.
l Procedure PMD-60-013, " Program Description for ALARA" (Draft), . Revision 0, not dated.
. I Procedure HP-1-220, Administrative Procedure - Bioassay Program," . Revision 1, December 9, 1981.
Procedure HP-2-105, " Health Physics Procedure - Urine and Fecal . Sampling Techniques," Revision 0, August 24, 1981.
, ProcedureHP-1-102,"Administ'rativeProceddre-Respiratory .
Protection Program," Revision 0, January 7, 1982.
Procedure HP-1-218, " Admin ~.strative Procedure - Calculation of MPC . Hours," Revision 0, January 22, 1982.
- , Procedure HP-2-602, " Technical Procedure - Respiratory Protection . ' Quality Assurance Program" (Dfaf t), Revisioii 0, not dated.
. /.. I Procedure HP-1-110, " Administrative, Procedure - Radiation Work . Permits" (Draft), Revision 0_, not dated.
., ! Procedure HP-2-267, " Technical Procedure J Operation of the . , Respirator and Filter Check Station" (Draft), Revision 0, not
- *
dated.
, Procedure HP-1-161, " Technical Procedure - Use of the MSA . .
Air-Purifying Respirator," Revision 0, December 11, 1981.
'
Procedure HP-1-163, " Technical Procedure - Use of the MSA Airline . Respirator," Revision 0, January 7, 1982.
i L ,
. i M g h - /. .3 't ! -... :. +- ---, -. - - - -
r
. 2' Procedure HP-1-165, " Technical Procedure - Use of the MSA ' . Self-Contained Breathing Apparatus," Revision 0, January 22, 1982.
< Procedure HP-1-219, " Administrative Procedure - Radiological [ . Posting Requirements," Revision 1, September 2, 1981.
. f Procedure HP-2-215, " Technical Procedure - Airborne Survey ! . Techniques," Revision 0, August 12, 1981.
i Procedure HP-2-600," Health Physics Procedure - Control of l . Respiratory Protection Equipment," Revision 0, October 8,1982.
' Procedure HP-2-601, " Technical Procedure - Cleaning of Respiratory ' . Protection Equipment," Revision 0, January 22, 1982.
> Procedure HP-2-605, " Technical Procedure - Selection of Respiratory . , Equipment," Revision 0, January 22, 1982.
' , Procedure HP-2-625, " Technical Procedure - Maintenance of the FE . f{' 560A Nacl Aerosol Test System," Revision 0, January 7, 1982.
{ < % /. Procedure HP-2-631, " Technical Procedure - Operation of the ' . Breathing Air Fill Station" (Draft), Revision 0, not dated.
Procedure HP-2-637, " Technical Procedure - Verification of Minimum . Airflow to Respiratory Protection Devices" (Draft), Revision 0, February 9, 1982.
% Directive 82-2, " Health Physics Group Directive - Radiation, l . Contamination, Airborne Radioactive, and Exposure Guides and Limits," February 4, 1982.
l Procedure HP-2-604, " Technical Procedure - Medical Screening . Program," Revision 0, March 9, 1982.
Planned Documents Not Available for Review Procedure HP-1-217, " Administrative Procedure - Health Physics . Personnel Qualification Program," scheduled completion June 1982.
Procedure HP-2-350, " Health Physics Procedure - Operation of the . Whole Body Counter," scheduled completion June 198 * . Procedure HP-2-450, " Calibration Procedure - Calibration of the . Whole Body Counter," scheduled completion June 1982.
Procedure HP-2-352, " Health Physics Procedure - Operation of the . GeLi System," scheduled completion June 1982.
Procedure HP-2-452, " Calibration Procedure - Calibration of the . GeLi System," scheduled completion June 1982.
Procedure HP-2-635, " Technical Procedure - Breathing Air Quality . Testing of Air Supplies," scheduled completion May 1982.
(1) Internal Dosimetry Program The licensee had not fully established an internal dosimetry program at the time of this inspection.
The lic ensee had not received the complete whole-body counting system nor developed procedures for operation or calibration of the system.
The licensee stated that the whole-body counting system should be ready for operation on October 1, 1982; and completion of baseline invivo surveys of station personnel by January 15, 1983.
The gamma pulse height analyzer - used in analyzing airborne samples - is scheduled for operation by August 1, 1982.
The inspectors noted that insufficient instructions were provided in procedure HP-2-105, for the packaging and shipping of excreta samples, to ensure that samples are properly packaged and shipped to offsite analytical laboratories, with no resultant sample loss or damage.
Furthermore, no provisions had been established to provide QA/QC instructions for excreta analysis by offsite laboratories or for onsite invivo measurement activities.
Also, the licensee had not established procedures for the back calculating of MPC-hours based on bioassay results.
This item is considered open (82-04/06) pending: Development of operating and calibration procedures for the . whole-body counting system.
, - _
.- . - - - - _.- . _ _. !
' , l >
t t i The evaluation of procedures for packaging and shipment of
.
excreta samples to offsite laboratories.
Development of a QA/QC program for the bioassay program to . include offsite analytical services.
Completion of baseline bioassay for station personnel.
. j Development of procedures that provide for back-calculation . , i of MPC-hours, based bioassay results.
i i (2) Respiratory Protection Program , The licensee had described a respiratory protection program in procedure HP-1-102.
This procedure contains a statement on ! Louisiana Power and Light Company's commitment to a respiratory protection program; however, the inspectors noted that this ! commitment was issued by the station manager.
The NRC staff does not consider this commitment to be in agreement with Regulatory Guide 8.15, which requires a written policy on respiratory protection usage from a h M management level.
The licensee had issued only 20 out of a total of approximately 30 ! ' procedures that implement the respiratory protection program.
Key procedures not issued at the time of the
inspection included: gamma spectra analysis, whole-body ' counting, breathing air quality control, respiratory protection quality assurance, operation of breathing air cylinder filling station, verification of minimum air flow to respiratory protection devices, and inspection and maintenance of respiratory protection equipment.
The inventory of respiratory protection equipment present during ' this inspection is shown below: , Respiratory Protection , Equipment Model No. on Hand SCBA* TC-13F-30 76 units I SCBA Air Cylinders N/A 227 Air Cylinders
Full Face Air Purifying TC-21C-186 434 Respirators , ! " i Full Face Air Purifying TC-21C-186 10 Units t
(Powered) {
- Self-Contained Breathing Apparatus
. . -.., - _ _ ._. _ ,-_ _ ... _. .
._ _ ___ ,
l
. l The inventory also contained support equipment for adapting approximately 30 full-face respirators to the airline type respirators.
The above inventory does not contain the 20 hood type - airline air supplied respirators - committed to by the licensee in the FSAR.
The inspectors noted that the licensee had not installed a suitable supply of breathing air for airline respirators.
Discussions with the licensee determined that this area was being investigated and actions would be taken to provide suitable breathing air.
The licensee is also evaluating air fed hoods from several manufacturers for possible procurement.
The inspectors noted that the licensee had a breathing air compressor for filling SCBA cylinders, but had not installed or operationally checked i t.
The inspectors noted that the licensee has included procedures that provide for the individual fitting of respirator users and the medical screening of personnel prior
to approval as a respirator user.
These areas of the program l appear to agree with the requirements of Regulatory Guide 8.15.
However, the inspectors noted the lack of instructions that would ensure only properly certified personnel repaired, maintained, and man-fit respiratory protection equipment.
The inspectors noted that the specified respirator protection factors provided generally agreed with those in Regulatory Guide 8.15, with the exception of the protection factor of 1,000 assigned to air fed hoods, with air flows of less than or equal to 6 cubic feet per minute (cfm), of which no certification per Section C.7 of Regulatory Guide 8.15 can be determined. The inspectors noted that the licensee had not completed procurement of all airborne radioactivity monitoring equipment and only had on hand semi-fixed station gross beta, continuous activity monitors.
The licensee is having problems in , procuring multi phase continuous airborne monitors as committed to in the FsAR.
The inspectors determined that the licensee had not established procedures for the calibration of airborne radioactivity
' sampling equipment as recommended by Regulatory Guide 8.25.
[ The licensee's plans on monitoring airborne radioactivity in t work areas using grab-type airborne sampling instruments (high i volume air samplers).
There is a question of the adequacy of this i approach for determining representative concentrations of
radionuclides in the worker's breathing zone to ensure that-I worker's intake of radionuclides is controlled in accordance with the requirements of 10 CFR 20.103.
The licensee stated , that they would evaluate the use of lapel-type samplers in their l l _ - --. . .
.-.. _-_ - .. .. . - -- . -_ - .... - _ =. -.
,
, respiratory protection program in order to satisfy the requirements of 10 CFR 20.103 and 10 CFR 20.201. The inspectors also noted that routine airborne alpha activity determinations are not provided for in procedures; and that action levels for posting areas requiring respiratory protection due to loose , surface contamination (alpha and beta gamma) had not been provided.
J This item is considered open (82-04/07) pending:
The issuance of a corporate policy statement on respiratory . i protection.
Completion of respiratory protection program procedures.
. Procurement of remaining respiratory protection . equipment and continuous work area airborne contamination (gas, iodine, and particulate) monitoring equipment.
Procurement of a suitable breathing air supply system for , . airline respirator users.
. Development of calibration procedures for airborne . contamination sampling devices.
Providing approved respiratory protection factors for .
air-supplied hood use at various flow rates.
. Development of instructions for the identification of airborne . alpha radioactivity in work areas and action levels for ' implementation of respiratory protection based on loose surface contamination limits for all types of radioactive _ contamination to be encountered.
Development of procedures and procurement of equipment that . , will ensure representative sampling of worker's breathing
Zone.
(c) Radiological Surveys The inspectors reviewed the licensee's survey program to , determine compliance with: FSAR commitments; the requirements ' ' of 10 CFR 20.20lb and 10 CFR 20.40lb, and the recommendations
of NRC's Decontamination Guidelines - 1976, ANSI N13.12-1978, i and NUREG-0761.
' , l - _ _ _ .
.- __ .- __. _ _ _.. _ _ _ _ - _. . . , o I i i
. .
i Documents Reviewed ) FSAR Sections 12.5.1.3, 12.5.3.1, 12.5.3.5, and 12.5.3.8.
. Procedure HP-1-100, " Administrative Procedure - Health Physics . Manual" (Draft-2), Revision 0.
! , !
Procedure HP-1-201, " Administrative Procedure - Scheduling of i . Routine Health Physics Activities," Revision 1, dated ! j December 9, 1981.
' t Procedure H-1-110, " Administrative Procedure - Radiation Work
. Permits" (Draft), Revision O.
Directive 82-2, " Health Physics Group Directive - Radiation, . " Contamination, Airborne Radioactivity, and Exposure Guides and Limits," February 4,1982.
! Procedure HP-1-218 " Administrative Procedure - Calculation of
. j MPC hours," Revision 0, January 22, 1982.
i Procedure HP-2-201, " Health Physics Procedure - Radiation . e Survey Techniques," Revision 1, September 28, 1981.
, Procedure HP-2-210, " Technical Procedure - Contamination Survey . Techniques," Revision 0, September 28, 1981.
, l Procedure HP-2-215, " Technical Procedure - Airborne Survey
. Techniques," Revision 0, August 12, 1981.
i
Procedure HP-2-216, " Technical Procedure - Air Sample Analysis . and Evaluation," Revision 0, August 12, 1981.
F Procedure HP-2-801, " Technical Procedure - Removal of Equipment i . and Material from a Radiation Controlled Area," Revision 1,
September 28, 1981.
i Procedure HP-806, " Surveillance Procedure - Leak Testing of
. Sealed Sources," Revision 1, January 22, 1982.
- s
! Procedure HP-2-812, " Technical Procedure - Receipt of . Radioactive Material," Revision 0, December 9, 1981.
, Procedure HP-2-700, " Technical Procedure - Laundry Handling and . Monitoring," Revision 0, August 12, 1981.
i e
(. _.
_. _. _. _. _ _ _ _ _ _ _ . - -. _ _, _ ._._ _, _ _ _ _., _ _,, - -... _ _ _. _ - . _ _.,.
- Procedure HP-2-601, " Technical Procedure - Cleaning of . Respiratory Protective Equipment," Revision 0, January 22, 1982.
' The licensee's basic radiological survey program is outlined in the draft Health Physics Manual, with survey frequency and techniques contained in various other supporting procedures.
Survey frequency ranges from per shift to annually.
The inspectors found that surface contamination surveys were deficient in the areas of: routine alphs activity analysis, and surveying of temporary and permanent lunch rooms, which is necessary to satisfy the requirements of 10 CFR 20.20lb and the recommendations of NUREG-0761.
The inspectors also noted that the loose surface contamination protective action limits for clean areas in procedures HP-2-806 and HP-2-817 were significantly higger (greater than 10 times) than the levels (500 dpm/100 cm beta / gamma) recommended by NUREG-0761.
The inspectors also noted that protective action levels were not established for loose surface contamination in regard to possible inhalation hazards.
This item is discussed in Section 8.b: Procedures have not been established to ensure that work areas being monitored by continuous airborne monitors (CAMS) are also periodically surveyed by grab-type sampling or personnel lapel samplers to verify that CAM results are representative of the worker's work and breathing zone.
The licensee's procedures for radiological surveying do not provide sufficient information for: (1) determination of the proper instrument to be used for a particular survey; or (2) measurement of beta exposure in situations involving work around internal surfaces, major plant equipment or areas extensively contaminated with high levels of radioactivity, as recommended by NUREG-0761.
Procedures were not available that
provided instructions on maintenance of survey records to satisfy the requirement of 10 CFR 20.401(c).
The licensee had not established a method of providing a comprehensive display of the radiological status of plant areas or instructions to ensure data is properly and timely recorded, and updates are made periodically as conditions change or new survey data is generated.
,
. . ._ - - _ _ _ '
> . This item is considered open (82-04/08) pending: Development of an alpha radioactivity survey program.
. Establishment of a routine survey program for all temporary . and permanent station eating facilities.
Development of consistent loose surface contamination . limits.
Development of instructions for breathing zone samples . ] to verify data provided by CAMS.
Establishment of a radiological survey record system.
.
Development of plant radiological status boards.
. d.
Radiation Work Permit (RWP) Program The inspectors reviewed the licensee's RWP Program (Draft) to determine compliance with FSAR commitments and recommendations of Regulatory Guides 1.33 and 8.8, and NUREG-0761.
' , Documents Reviewed ! ) FSAR Section 12.5.1.3 and 12.5.3.4.
. Procedure HP-1-100, " Administrative Procedure - Health Physics . Manual" (Draft 2), Revision 0, not dated.
Procedure HP-1-110, " Administrative Procedure - Radiation Work . Permits" (Draft), Revision 0, January 18, 1982.
The licensee's proposed RWP program does not appear to satisfy ,
the FSAR commitments nor the recommendations of Regulatory Guide 8.E in that provisions for specifying anticipated job
i dose commitments; establishing stay-times; specifying special training; specifying employees' allowable exposure; or providing job exposure history on the RWP form, are not provided.
The inspectors noted also that the draft procedures provided for the use of 7-day-old survey information for establishing initial radiological controls for RWP activities.
This does not appear to itisfy the requirements of 10 CFR 20.20lb.
This item is cons.kared open (82-05/09) pending licensee's completion of the program.
< ..,.. - ~- .ec.- - --,a
- 9.
ALARA The inspectors reviewed the licensee's ALARA program to determine agreement with FSAR commitments and recommendations of Regulatory Guides 8.8 and 8.10.
Documents Reviewed FSAR, Sections 11, 12, and 13.
. Procedure HP-1-101, " Administrative Procedure ALARA Program . Implementation" (Draft), Revision 0, not dated.
Procedure PMD-60-013, " Program Description for ALARA" (Draft), . Revision 0, not dated.
Procedure HP-1-104, "ALARA Cost-Benefit Evaluation" (Draf t), . Revision 0, not dated.
Procedure HP-1-203, "ALARA Committee Operation" (Draft), . Revision t, not dated.
Procedure HP-1-105, "ALARA Problem Report" (Draf t), Revision 0, . not dated.
The licensee's proposed ALARA Program appeared to satisfy most of the recommendations contained in Regulatory Guides 8.8 and 8.10.
This item is considered open (82-04/10) pending completion of the proposed program.
10.
Radiological Posting and Labeling The inspectors reviewed the licensee's program for posting and labeling of designated areas to determine compliance with 10 CFR 19.11, 10 CFR 20.202, 10 CFR 20.203b, 10 CFR 20.203.c, 10 CFR 20.203.d, 10 CFR 20.203.e, 10 CFR 20.203.f, and 10 CFR 20.207 requirements.
Documents Reviewed Procedure HP-1-100, " Administrative Procedure - Health Physics Manual" . (Draft 2), Revision 0, not dated.
Procedure HP-1-152, " Technical Procedure - Marking, Handling, and . Storage of Tools and Equipment," Revision 1, September 29, 1981.
t
- . Procedure HP-1-219, " Administrative Procedure - Radiological Posting," . Revision 1, September 2,1981.
Procedure HP-1-107, " Administrative Procedure - High Radiation Area and . Locked High Radiation Area Access Control" (Draft), Revision 0, January 21, 1982.
The inspectors determined that the licensee's program was not fully established. However, the planned program appears to satisfy 10 CFR 20 requirements.
This item is considered open (82-04/11) pending completion of the proposed program.
11.
Notifications and Reports The inspectors examined the licensee's planned program for submitting required notifications and reports to determine compliance with the requirements of 10 CFR 19.13, 10 CFR 20.402, 10 CFR 20.403, 10 CFR 20.405, 10 CFR 20.407, 10 CFR 20.408, and the recommendations of Regulatory Guides 1.16 and 10.1.
Documents Reviewed Procedure HP-1-100, " Administrative Procedure - Health Physics Manual" . (Draft 2), Revision 0, not dated.
Procedure HP-1-215 " Health Physics Procedure - NRC Radiological . Reporting Requirements" (Draft 1), Revision 0, not dated.
The licensee's proposed reporting program appeared to satisfy the requirements contained in 10 CFR 19 and 10 CFR 20 and the recommendation contained in Regulatory Guide 1.16 and 10.1, with the exception of bicassay reports as discussed in Section 8.a, of this report.
This item is considered open (82-04/12) pending completion of the proposed program.
12.
Protective Equipment and Supplies The inspectors reviewed the licensee's inventory of_ protective equipment and supplies for such items as anticontamination clothing, radiological warning signs and labels, personnel decontamination supplies, step-off pads, respirators, etc., to determine compliance with FSAR commitments and the recommendations of NUREG-076. ! Documents Reviewed
FSAR Section 12.5.2.2.4.
. The licensee had not completed procurement of all necessary equipment nor established equipment inventory procedures.
The licensee has scheduled ' completion of protective equipment procurement and inventory control for about June 1, 1982.
This item is considered open (82-04/13) pending: , Procurement of protective equipment and supplies.
. Establishment of an inventory system for radiological protective . equipment and supplies.
13.
Radiation Protection Instrumentation The inspectors reviewed the licensee's radiation protection instrumentation program to determine agreement with: FSAR commitments, and the recommendations of Regulatory Guides 8.4 and 8.25, ANSI N323-1978, and NUREG-0761.
Documents Reviewed FSAR Section 12.5.2.2; Tables 12.5-1, 12.5-2, 12.5-3, and 12.5-4.
j . Procedure HP-1-210, "Adminstrative Procedure - Health Physics Instrument . Control Program," Revision 1, February 5, 1982.
Procedure HP-1-151, " Technical Procedure - Use of Self-Reading Pocket . Dosimeters" (Draft), Revision 2, October 9, 1981.
Procedure HP-2-300, " Technical Procedure - Operation of the Eberline . PIC-6A," Revision 0, September 28, 1981.
Procedure HP-2-400, " Calibration Procedure - Calibration of the Eberline . PIC-6A," Revision 0, January 22, 1982.
Procedure HP-2-302, " Technical Procedure - Operation of the Eberline . Teletector," Revision 0, February 18, 1982.
Procedure HP-2-402, " Calibration Procedure - Calibration of the Eberline . Teletector," Revision 0, February 18, 1982.
. L
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, i
- . . ' Procedure HP-2-303, "Technica' Procedure - Operation of the Eberline . E-520," Revision 0, December 31, 1981.
Procedure HP-2-403, " Calibration Procedure - Calibration of the . Eberline E-520," Revision 0, January 22, 1982.
Procedure HP-2-304, " Technical Procedure - Operation of the Eberline . PRS-2/NRD" (Draft), Revision 0, not dated-i i ' Procedure HP-2-308, " Technical Procedure - Operation of the Ludlum 177," . Revision 0, November 11, 1981.
Procedure HP-408, " Calibration Procedure - Calibration of the . Ludlum 177," Revision 0, December 11, 1981.
. Procedure HP-2-309, " Technical Procedure - Operation of the Eberline . R0-2 and R0-2A," Revision 0, September 10, 1981.
i Procedure HP-2-409, " Calibration Procedure - Calibration of the Eberline ' . R0-2 and R0-2A," Revision 0, December 9, 1981.
Procedure HP-2-412, " Calibration Procedure - Calibration of the Ludlum 12," . Revision 0, January 7,1982.
Procedure HP-2-314, " Technical Procedure - Operation of the Ludlum 12s," . Revision 0, September 28, 1981.
! l Procedure HP-2-320, " Technical Procedure - Operation of the RADeCo ' . H809V," Revision 0, September 28, 1981.
a I Procedure HP-2-321, " Technical Procedure - Operation of the RADeCo . H809C," Revision 0, September 28, 1981.
Procedure HP-2-322, " Technical Procedure - Operation of the Eberline . RAS-1," Revision 0, September 10, 1981.
! Procedure HP-326, " Technical Procedure - Operation of the Eberline .
AMS-3," Revision 0, October 1, 1981.
Procedure HP-2-330, " Technical Procedure - Operation of the Eberline . MS-2," Revision 0, January 22, 1982.
Procedure HP-2-331, " Technical Procedure - Operation of the Eberline . BC-4," Revision 0, January 22, 1982.
i , Procedure HP-2-332, " Technical Procedure - Operation of the ! . NMC ASC-75," Revision 0, February 18, 1982.
i - ! , . -, - - _ , _ _. - . _-- ..,..- .. - - -,m-- ,+ r
_ . . . _ _ .-
' - . Procedure HP-333, " Technical Procedure - Operation of the Ludlum Scaler . 2000" (Draft), Revision 0, not dated.
Procedure HP-2-334, " Technical Procedure - Operation of the Ludlum Model . ' 2218 Dual Stabilized Analyzer" (Draft), Revision 0, January 29, 1982.
Procedure HP-2-337, " Technical Procedure - Operation of the DCA Area . Alarm Monitor 3090," Revision 0, January 25, 1982.
Procedure HP-2-437, " Calibration Procedure - Calibration of the DCA Area . Alarm Monitor 3090," Revision 0, March 9, 1982.
Procedure HP-2-441, " Calibration Procedure - Operational Checks of the . IRT Portal Monitor" (Draft)," Revision 0, January 28, 1982.
r Procedure HP-2-470, " Calibration Procedure - Statistical Check of . Counters / Scalers," Revision 0, January 7, 1982.
Procedure HP-2-500, " Health Physics Procedure - Operation and Use of the . Victoreen Condenser R-Meter and R-Chambers," Revision 0, August 10, 1981.
, . Procedure HP-2-501, " Technical Procedure - Verification of Calibration of the Victoreen Condenser R-Meter and R-Chamber," Revision 1, February 5, 1982.
Procedure HP-2-502, " Technical Procedure - Operation and Use of the . Eberline 1000B," Revision 0, June 15, 1981.
Procedure HP-2-503, " Surveillance Procedure - Calibration of the . Eberline 1000B," Revision 0, September 10, 1981.
' Procedure HP-2-504, " Health Physics Procedure - Verification of . Calibration of the Eberline 1000B," Revision 0, August 12, 1981.
Procedure HP-2-506, " Technical Procedure - Use of the 12 mci Cs-137 . Source for Calibration of Environmental TLD's," Revision 0, December 31, 1981.
Procedure HP-2-507, " Technical Procedure - Calibration of the 12 mci . Cs-137 Source," Revision 1, January 7, 1982.
i Procedure HP-2-508, " Technical Procedure - Verification of Calibration . of the 12 mci Cs-137 Source," Revision 0, January 7, 1982 .
, f .- , _, _ _ _... .. _ _ _ _. -.. -_ _.
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1
- , Proposed Documents Not Available for Review < Procedure hP-2-313, " Operation of the Reuter Stokes Pressurized Ion . Chamber." Scheduled implementation May 1982.
Procedure HP-2-325, " Operation of the NMC Continuous Air Monitors."
. Scheduled implementation July 1982.
Procedure HP-2-350, " Operation of the Whole Body Counter." Scheduled ' . implementation June 1982.
Procedure HP-2-351, " Operation of the Panasonic Automatic TLD Reader . VD-710A." Scheduled implementation mid-July 1982.
Procedure HP-2-352, " Operation of the GeLi System." Scheduled . implementation June 1982.
<
Procedure HP-2-353, " Operation of the Panasonic Manual TLD Reader . j VD-702E." Scheduled implementation mid-July 1982.
l t Procedure HP-2-360, " Operation of the Radiation Monitoring System
. Console." Scheduled implementation unknown.
.
Procedure HP-2-414, " Calibration of the Ludlum 12s." Scheduled . implementation July 1982.
Proceduce HP-2-425, " Calibration of the NMC Continuous Air Monitor."
. Scheduled implementation July 1982.
i ! Procedure HP-2-426, " Calibration of the Eberline AMS-3."
Scheduled . j implementation July 1982.
i Procedure HP-2-430, " Calibration of the Eberline SPA-3 with MS-2."
' . Scheduled implementation July 1982.
Procedure HP-2-450, " Calibration of the Whole Body Counter." Scheduled . l implementation June 1982.
. Procedure HP-2-471, " Calibration of Air Sampler Flowmeters." Scheduled . l implementation July 1982.
i Procedure HP-2-471, " Calibration of the Eberline RAS-1."
Scheduled . l implementation July 1982.
i i i
.
. Listed below is an on-hand station inventory of radiation protection instruments with reference to FSAR commitments.
FSAR FSAR Required Quantity FSAR Instrument Range Manufacturer On-hand Requirements Gas Flow 0-E+7 c/m Nuclear Measure-
2 Proportional ments (ACS-75) GM Counter 0-E+5 c/m Eberline (BC-4)
2 Counter Scaler Ludlum (2000)
0 Counter Scaler Johnson & Assoc.
0 Counter Scaler Eberline (MS-2)
0 Counter Scaler / Ludlum (2218)
0 Analyzer Liquid Scin-
1 tillation Counter Ge(Li) Detector Princeton
1 Gamma Tech.
Portable Instruments Alpha Survey 0-E+5 c/m
2 meter (Gas Flow) Alpha Survey Ludlum 12/43-5
0 Meter (Scintillation) Neutron Survey 0-5 Rem /h Eberline (PRS-2P/
2 Meter NRD) GM Survey 0-E+3 Rem /h Eberline (Teletector 10
Meter 6112) (Telescoping Probe) GM Survey 0-2.0E+3 Eberline (E-520)
8 Meter mrem /h .
. ._.
... . - _. _ _ _. - . - _ _ - - _. _.
- _ ! I i
- . l FSAR FSAR Required Quantity FSAR , Instrument Range Manufacturer On-hand Requirements J j GM Survey 0-E+4 c/m Ludlum (12)
4 Meter
! Ion Chamber 0-E+3 Rem /h Eberline
10 Survey Meter (PIC-6A) , . ! ' Ion Chamber 0-5.0E+3 Eberline (RO-2)
15
Survey Meter mrem /h I lon Chamber 0-5.0E+4 Eberline (RO-2A)
15 Survey Meter mrem /h {
Floor Monitor 0-E+5 c/m
1 i (GM) ! GM Personnel 0-E+5 c/m Ludlum (177)
8
Survey I (Friskers) Portal 0-E+3 c/m IRT*
2 Monitors PRM-110 (Scintillation)
- (Equivalent)
, to GM unit) Hand and 0-E+4 c/m
1 Foot Counters ! i l Whole Body 0-Several
1 Counter organ burdens Direct 0-200 mR N/A 524
reading 0-1R 150 100 , , dosimeters 0-10P.
0
. 0-500 mR
300 '
0-5R
10 Dosimeters N/A
4 Chargers , High Volume 4-10 ft.3/ min.
RADECO
4 . Air Sampler H809V Air Sampler RADECO
0
(Battery Powered) H809C Air Sampler Eberline
0 (Low Volume) (RAS-1) I l ! < r -. ... . - .,._.
c ., .__... - - -.. _ _ ,,,. . _,. -
- - - . - - . -- -- l !
' . l
FSAR FSAR Required Quantity FSAR i Instrument Range Manufacturer On-hand Requirements i Portable Particulate Particulate Only
5 ' 1.0E-10-1.0E-7 Eberline (AMS-3)
Gas 1.0E-7- ' 1.0E-4 Instrument .002-500 Rem
1 Calibrator Eberline 1000B ' l The licensee had not completed procurement of all radiation protection instrumentation as committed to in the FSAR.
The licensee is having difficulty obtaining multifunction portable continuous air monitors from the contracted vendor.
l The inspectors noted that the FSAR commits the licensee to procurement of j a gas-type portable alpha radiation detection system whereas the licensee ! has purchased scintillation-type alpha survey instruments.
However, these appear to be a satisfactory substitute for gas-type systems specified in the FSAR.
Also, the licensee had committed to the use of self-reading pocket chambers in the ranges of 0-200 mr, 0-500 mr, 0-1R, and 0-5R; however, current inventory showed only 0-200 mr, 0-1R, and 0-10R dosimeters. This inventory of pocket dosimeters appears to be of sufficient range to satisfy station needs.
The inspectors noted that the licensee's calibration program provides j for semiannual calibration of radiation protection instrumentation.
' NUREG-0761 recommends that calibration of radiation orotection instrumentation, especially portable dose rate measurement instruments, , j should occur at a frequency of not less than quarterly (every 3 months).
The licensee's calibration procedures qualify only as, " Periodic Performance . Tests" as referenced in Section 4.6 of ANSI N323-1978, or " Secondary l Calibrations" as referenced in Section 8.b.(2) of NUREG-0761.
The licensee had not, at the time of the inspection, issued instructions for the periodic (prior to use) performance test of radiation protection l instruments as recommended by Section 4.5 of ANSI N323-1978.
i j i .
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. . The inspectors further noted that: the licensee had not established a quality control program to ensure that GM-type detectors, used for personnel and material frisking surveys, met the manufacturers specifications, or included these detectors in the instrument calibration procedures. This calibration of defectors is considered necessary in order to determine that the complete unit (detector / count rate meter) could detect licensee-specified limits of radioactivity.
Also, the inspectors noted that the licensee's proposed instrument program did not include operational or calibration procedures for alpha survey instrumentation.
The licensee's proposed beta calibration program will use a slab of depleted uranium that will produce a beta dose rate between 180 and 225 millirads per hour. This appears to be insufficient to provide survey instrument calibration on all instrument ranges expected to be encountered, as recommended by ANSI N323-1978.
The inspectors noted that Deta levels often occur in the range of 1 to 10 rads /h ' during work on the interior surfaces of major plant equipment (such as the primary side of steam generators or the underside of the reactor vessel head) during maintenance operations, and that the licensee's present beta calibration program would not ensure accurate dose rate measurements at these elevated levels.
The inspectors further noted that the DCA area alarm monitors (fixed position gamma radiation monitor) appear not to be equipped with an instrument failure alarm, which does not satisfy the recommendation of ANSI /ANS-6.8.1 " Location and Design for Area Radiation Monitoring Systems for Light Water Nuclear Reactors."
Discussions with the licensee determined that they were evaluating a proposal to have their neutron dose rate measurement instruments calibrated by an offsite contractor in order to meet the calibration criteria established in ANSI N323-1978.
The inspectors noted that the licensee did not include in station procedures, provisions for HP Group review of in plant radiological monitor systems alarm set points.
The inspectors also noted that the licensee's primary instrument calibrator, according to manufacturer's specifications, does not appear to be able to provide calibrated dose rates for the check points at 80 percent full scale on the upper scale of the licensee's two types of high-range radiation monitoring instruments, as recommended by ANSI N323-1978.
Discussions with licensee concerning this item indicated that their instrument calibrator had a useful range of ' only 500 R/h and some of their instruments are designed to measure dose rates at 1000 R/h.
Also, the inspectors determined that procedures for l calibration of instruments provided insufficient instructions on i radiation safety during use of high-activity calibration sources.
l The licensee's TLD, Whole-Body Counter, and Gamma Spectrum Systems are discussed in Section 8 of this report.
This item is considered open (82-04/14) pending: ! l I J
_ _
' . i Procurement of radiation protection instruments.
. Completion of operational and/or calibration procedures for: . t ' Neutron instrumentation.
. Continuous air monitors.
. Alpha Survey instruments.
. Air particulate samplers.
. . High-range beta survey instruments.
. Evaluation of the instrument program in the following areas: . Calibration frequency of instrumentation.
. Radiation protection during calibration operations.
. Qualification of area radiation monitors.
. Establishing a primary calibration program in regard to the . recommendations of ANSI N323-1978.
Implementation of a calibration program for count ratemeters and . associated GM detectors (Friskers).
Implementation of an instrument response test program.
. 14.
Facilities
The inspectors visited and reviewed the facilities to be used by the , HP Group staff in carrying out their various health physics
functions.
Since little guidance is available to determine the adequacy of such facilities, inspection findings are based on the inspector's judgment and comparison with practices at other similar nuclear power plants. The following facilities were observed: Area Location Status Health physics office-4ft. elevation RAB* Completed, not and access control area equipped or occupied , i Health physics equipment-4ft. elevation inside Completed, used for storage and work area Auxiliary Building instrument storage and issue i .,. -. . _ -.. _,. ., ,
. . Personnel decontamination-4ft. elevation RAB Not completely area operational Count room +7ft. elevation RAB Proposed Respiratory protection +7ft. elevation RAB Proposed Health physics storage +7ft. elevation RAB Proposed Health physics supervisors +7ft. elevation RAB Proposed office First-aid area-4ft. elevation RAB Incomplete, proposed Protective clothing +7ft. and -4ft.
Incomplete, change room and employee elevation RAB proposea lockers Laundry Facility-4ft. elevation RAB Incomplete
- Reactor Access Building The Health Physics office, RWP issue point, and Radiation Controlled Area (RCA) entry / exit appear to be as committed to in the FSAR; even though, construction is still (at time of inspection) in progress.
The proposed control point monitor's position appears to provide him/her with visual control over entry and exit activities taking place at the RAB boundary on the -4 ft. elevation, adjacent to the Health Physics office.
There appears to be sufficient space for worker dressing and sanitary facilities for both men and women.
The licensee has not completed construction of all necessary space for health physics activities.
The proposed space on the +7 ft. elevation for the health physics alternate office, count room, and respiratory protection program shops is also the same area referenced in an open item (81-16/04), previously identified on NRC Inspection Report 50-382/81-16.
The licensee stated that evaluation of this open item is still being carried out by LP&L management.
The inspectors reviewed the laundry facility and proposed respiratory equipment decontamination, cleaning, and sanitizing facility.
The licensee stated that plans were being developed to contract offsite laundry services for decontamination of used anticontamination clothing and possibly not even use the laundry space, except for minor amounts of station generated laundry during non-outage periodr., and respirator cleaning.
This item is considered open (82-04/15) pending completion of health physics facilities.
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' - 15.
Audits and Review The inspectors reviewed the licensee's interr $1 audit / review program regarding radiation protection activities to determine compliance with FSAR commitments, the requirements of 10 CFR 50, Appendix B, and the recommendations of ANSI N18.7-1976, N45.2.12-1977, Regulatory Guide 1.144, and NUREG-0761.
Documents Reviewed Safety Evaluation Report (NUREG-0787) Waterford Unit No. 3.
. LP&L Quality Assurance Manual.
. The inspectors were specifically interested in the existence of audit / review programs and the scope of these programs for the following areas: Reviews performed by supervision within the HP Group of such . activities as staff effectiveness, work practices, adequacy of training, and procedural compliance.
Reviews performed by the onsite Quality Control (QC) Department.
. Corporate audits / evaluations to ensure compliance with Technical . Specifications and stated objectives.
Audit / review format, including the existence of audit procedures and . checklists, to provide an insight regarding the adequacy and scope of proposed audit / review activities.
The composition of audit / review teams to ensure that team members . possess the necessary expertise to properly evaluate the assigned
areas.
A corrective action program for timely resolution of identified . deficiencies.
The licensee stated that a detailed audit / review program covering the above items had not been developed.
According to the licensee, it is , l their intention to develop and implement a comprehensive audit / review ! program prior to fuel loading.
This item is considered open (82-04/16) peading the development of an audit / review program for radiation protection activities.
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. 16.
Start-up Surveys The inspectors reviewed licensee procedures for radiation surveys of plant shielding during initial plant startup to determine compliance with FSAR commitments.
! Documents Reviewed , Procedure SIT-TP-715 " Start-up Integrated Test - Biological Shield ( . Effectiveness Survey" (Dreft), Revision 1, dated February 22, 1982.
Test Procedure SIT-TP-715 provides for specific gamma and neutron dose rate surveys at preselected and marked locations at zero power (background), 5% power,10% power, 20% power, 50% power, and 100% power.
The inspectors were concerned that the draft procedure did not contain the survey data sheets for determining location and marking of survey points.
The inspectors noted the startup survey program did not include a study of plant air flow characteristics.
This is considered an important assessment to ensure airborne contamination levels of spaces normally occupied by personnel are maintained ALARA.
This item is considered open (82-04/17) pending: Completion of procedure SIT-TP-715.
. Development of a program to determine plant air flow characteristics.
. 17.
Procedures The inspectors reviewed the licensee's HP Group procedures, both approved and those in draft form, to determine compliance with 10 CFR 20 requirements, and recommendations contained in Regulatory Guides 1.33, 4.13, 7.3, 8.15, 8.8, 8.9, 8.25, 10.1; ANSI N13.1-1969, N13.11, N13.12, N13.5-1972, N13.6-1966 (R 1972), N18.7-1976, N322-1977, and N323-1978; and NUREG-0761.
For documentation purposes, in this report, the licensee's procedures have been classified as either: (1) Procedures that Appear to be ' Satisfactory, (2) Procedures with Problems, and (3) Procedures to be Completed.
All procedural findings will appear under one open item.
The inspectors noted that the licensee has approved and issued i approximately 66 percent (81 Procedures) of all scheduled health physics procedures, with approximately 43 procedures remaining to be approved and issued.
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Procedures that Appear to be Satisfactory
' hP-1-161, "Use of the MSA Air-Purifying Respirator," Revision 0, . Decerher 11, 1981.
HP-1-228, " Annual Land Use Survey," Revision 0, February 18, 1982.
. HP-2-106, " Noble Gas Equivalent Calculation," Revision 0, March 8, , l . l 1982.
HP-2-470, " Statistical Check of Counter / Scalers," Revision 0, . , l January 7, 1982.
. HP-2-604, " Medical Screening Program," Revision 0, March 9,1982.
. HP-2-626, " Maintenance of the FE560A Nacl Aerosol Test System," . . Revision 0, January 7, 1982.
' i HP-2-900, " Collection and Preparation of Surface Water Samples," l .
Revision 1, September 10, 1981.
, , HP-2-901, " Collection and Preparation of Drinking Water Samples," I . Revision 1, December 31, 1981.
HP-2-902, " Collection and Preparation of Milk Samples," Revision 1, . September 28, 1981.
HP-2-903, " Collection and Preparation of Ground Water Samples," . Revision 1, November 9, 1981.
HP-2-904, " Collection and Preparation of Shore Sediment Samples," .
Revision 1, October 1, 1981.
HP-2-905, " Collection and Preparation of Grass Samples," ' . Revision 1, November 9, 1981.
, l HP-2-906, " Collection and Preparation of Vegetable Samples," . Revision 1, November 9, 1981.
HP-907, " Collection and Preparation of Aquatic Biota and Bottom ' . Sediment Samples," Revision 1, December 31, 1981.
' l ! HP-2-908, " Collection and Preparation of Air Samples," Revision 1, " . l December 31, 1981.
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- . HP-2-909, " Collection and Preparation of Thermoluminescent . Dosimeters," Revision 0, July 31, 1979.
HP-2-911, " Sample Shipment," Revision 1, December 31, 1981.
. HP-2-805, " Radioactive Material Accountability," Revision 1, . August 10, 1981.
b.
Procedures with Problems Some of the procedures listed below had minor deficiencies, such as, referencing of nonexistent procedures; and others appeared not to agree or comply with various requirements or commitments.
HP-1-102, " Respiratory Protection Program," Revision 0, January 7, . 1982.
HP-1-165, "Use of the MSA Self-Contained Breathing Apparatus," . Revision 0, January 22, 1982.
HP-2-300, " Operation of the PIC-6A," Revision 0. September 28, 1981.
. HP-2-302, " Operation of the Eberline Teletector," Revision 0, . September 10, 1981.
HP-2-303, " Operation of the Eberline E-520," Revision 0, . December 31, 1981.
HP-2-308, " Operation of the Ludlum 177, " Revision 0, November 11, . 1981.
HP-2-312, " Operation of the Ludlum 12," Revision 0, October 27, . 1981.
HP-2-314, " Operation of the Ludlum 12s," Revision 0, October 27, . 1981.
HP-2-320, " Operation of the RADeCo H809V," Revi; son 0, . September 28, 1981.
HP-2-321, " Operation of the RADeCo H809C," Revision 0, September 28, . 1981.
HP-2-322, " Operation of the Eberline RAS-1," Revision 0, . September 10, 1981.
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- HP-2-326, " Operation of the Eberline AMS-3," Revision 0, . January 22, 1982.
HP-2-330, " Operation of the Eberline MS-2," Revision 0, . January 22, 1982.
HP-2-331, " Operation of the Eberline BC-4," Revision 0, January 22, . 1982.
HP-2-332, " Operation of the NMC ASC-75," Revision 0, February 18, . 1982.
HP-2-500, " Operation and Use of the Victoreen Condenser R-Meter and . R-Chamber," Revision 0, August 10, 1981.
HP-2-502, " Operation and Use of the Eberline 1000B," Revision 0, . June 15, 1981.
? HP-2-505, " Operation and Use of the Eberline MP-1, Revision 0, . June 15, 1981.
Finding: Procedures reference nonapproved support procedures.
. HP-1-108, " Radiation Controlled Area Entry and Exit Requirements," . ' Revision 1, September 10, 1981.
Findings: Procedure references nonapproved support procedures.
Personnel training requirements (paragraph 5.2 A and B) do not match those in licensee's proposed Training Program and conflict , with those specified in paragraph 3.0 of HP-1-109.
HP-1-109, " External Radiation Exposure Control and Dosimetry . Issuance," Revision 0, December 9, 1981.
Findings: See comment on training and references above for HP-1-108.
Also, instructions for extremity monitoring, in regard to whole-body dosimetry, are not of sufficient detail to ensure that proper dosimetry is issued and worn by personnel using supplementary dosimetry.
This procedure also does not provide for accurate tracking of extremity exposure between TLD processing or periodic evaluation of dose received during instances of extremity exposure to high dose rates.
HP-1-112, " Radiological Infraction Reporting," Revision 0, . December 9, 1981.
Findings: Procedure references nonspproved support procedures.
This procedure does not provide for: expediently resolving infractions, notifying originator of actions taken, or trend analysis and auditing of the program effectiveness.
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- . HP-1-150, " Protective Clothing Requirements," Revision 1, . December 9, 1981.
Findings: Procedure does not provide for: minimum procurement specifications for anticontamination clothing, - on-hand stock requirements, and whether or not any special training or qualifications are required prior to using protective clothing.
HP-1-152, " Marking, Handling, and Storage of Tools and Equipment," . Revision 1, September 29, 1981.
Findings: Procedure provides loose surface contamination limits which are inconsistent with HP Group Directive 82-2; and fail to identify beta gamma and alpha activity limit requirements.
Procedure does not provide for: ensuring items are properly packaged prior to storage, periodic packaging integrity checks, surveys of storaged areas, or methods to ensure that an inventory reduction of stored equipment and tools is accomplished periodically.
.HP-1-161, "Use of the MSA Air-Purifying Respirator," Revision 0, December 11, 1981.
Findings: Procedure does not provide protection factor limits or reference the licensee's respirator selection program.
This procedure does not appear to provide a suitable field fit test of respirators prior to use.
NUREG-0041 requires that the less satisfactory positive and negative pressure fit tests of respirators be only used if a challenging atomsphere, i.e., smoke or other irritant, cannot be used to test fit respirator users prior to each respirator use.
The licensee's procedure i will allow respirator use when only a pressure test is used ! without requiring use of a challenging atmosphere test.
HP-1-163, "Use of the MSA Airline," Revision 0, January 1982.
. Findings: Procedure does not provide protection factors or reference the licensee's respirator selection procedure.
This procedure does not appear to provide a suitable field fit test of , ' respirator prior to respirator use.
The inspectors find the title of this procedure misleading.
HP-1-201, " Scheduling of Routine Health Physics Activities," . Revision 1, December 9, 1981.
Findings: Procedure references nonapproved support procedures.
Survey frequencies and survey areas are discussed in Section 8.c of.this report.
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- . HP-1-210, " Health Physics Instrument Control Program," Revision 1,
. February 5, 1982.
Findings: Procedure references nonapproved support procedure.
Procedure does not provide for a QA/QC program for offsite vendors that perform instrument calibration.
HP-1-216, " Investigation of Radiological Occurrences," Revision 0, . December 9, 1981.
Findings: Procedure references nonapproved support procedures.
Form HP-AD-1 does not provide for evaluations of actions taken to ensure corrective actions were effective.
HP-2-605, " Selection of Respiratory Equipment," Revision 0, . January 22, 1982.
HP-2-218, " Calculation of MPC nours," Revision 0, January 22, 1982.
. Finding: Procedures use a respiratory protection factor that does not appear to be in accordance with 10 CFR 20.103(c) for air fed hoods when air flow is equal to 6 cfm.
, HP-1-219, " Radiological Posting Requirement," Revision 1, . September 2, 1981.
Finding: Procedure references nonapproved support procedures.
Procedure does not contain high level contamination posting limits for alpha contamination nor respiratory protection posting i requirements in regard to high levels of loose radioactivity.
' HP-1-220, " Bioassay Program," Re'ision 1, December 9, 1981.
, . l Finding: Procedure references nonapproved support procedures.
The procedure does not clearly define who must participate in the ! bioassay program; i.e., facility personnel, visitors, contractors.
The procedure indicates that a baseline bioassay will be performed when " participants" are assigned to the facility, but does not define participants.
The procedure should include information on an approved and available offsite medical consultant.
i HP-2-101, " Lost, Damaged, and Off Scale Dositnetry," Revision 0, . November 9, 1981.
HP-2-102, "Use of Self Reading Pocket Dosimeters," Revision 1, . September 10, 1981.
i HP-2-103, " Performance Check of Self-Reading Dosiineters," . Revision 0, December 9, 1981.
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45' , ' ' ', i , / ' + Findings: Procedures reference nonapproved support procedures.
- Procedure HP-2-103 does not specify a frequency of dosimeter
' performance check as recommended by Regulatory Guide 8.4.
- HP-2-105, " Urine and Fecal Sampling Techniques," Revision 0,
< . ' August 24, 1981.
- Findings: Procedure does not provide for: a minimum stock inventory of sample containers; an analysis results form to be sent with the samples to the offsite laboratory; and the offsite s laboratory is not identified for expediently dispatching of ~ , samples.
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HP-2-201, " Radiation Survey Techniques," Revision l', September 28, - . 1981 3;- Findings: Procedure references nonapproved support procedures.
_, The procedure does not provide information on the suitability
, ' of specific survey instruments for personnel dose rate surveys. The survey form, HP-SM-2, does not appear to be suitable for documentation of radiation surveys.
- HP-2-210, " Contamination Survey Techniques," Revision 0, . September 28, 1981.
- Findings:
Procedure references nonapproved support' procedures.
The procedure does not provide sufficient technical instructions to ensure swipes / smears counted with an HP-210 can detect the contamination limits desired.
HP-2-215, " Airborne Survey Techniques," Revision 0, August 12, . 1981.
j Findings: The procedure references nonapproved support procedures.
Insufficient instructions are provided to allow technicians to determine whether or not desired minimum detectable concentrations of radioisotopes can be detected / with volume of air sampled.
Procedure does not provide
-1 instructions on the use of lapel samplers for worker breathing zone monitoring.
See Section 8 of this report for additional information.
Procedure does not provide for airborne alpha radioactivity sampling.
i HP-2-216, " Air Sample Analysis and Evaluation," Revision 0, . Aggust 12, 1981.
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- Findings: Procedure references nonapproved support procedures.
Procedure does not provide for alpha activa t andysis of routine air samples.
HP-2-309, " Operation of the Eberline R0-2 and R0-2A," Revision 0, . September 10, 1981.
Findings: Procedure references nonapproved support documents. The R0-2A is not calibrated for beta radiation on the upper two scales and the procedure does not note this inherent beta measurement limitation of the instrument.
HP-2-337, " Operation of the DCA Area ALARA monitor 3090," . Revision 0, January 25, 1982.
Findings: Procedure references nonapproved support procedures.
Insufficent instructions are provided for placement of the instrument so as to preclude inadvertent shielding of the instrument.
HP-2-400, " Calibration of the Eberline PIC-6A," Revision 0, . January 22, 1982.
HP-2-402, " Calibration of the Eberline Teletector," Revision 0, . February 18, 1982.
HP-2-403, " Calibration of the Eberline E-520," Revision 0, . January 22, 1982.
, , / HP-2-504, " Verification of Calibration of the Eberline 1000B," . Revision 0, August 12, 1981.
, i HP-2-506, "Use of the 12 mci Cs-137 Source for Calibration of . ' Environmental TLD's," Revision 0, December 31, 1981.
HP-2-507, " Calibration of the 12 mci Cs-137 Source," Revision 1, . . ' January 7,1982.
. HP-2-508, " Verification of Calibration of the 12 mci Cs-137 - -' ' . Source," Revision 0, January 7, 1982.
HP-2-503, " Calibration of the Eberline 1000B," Revision 0, . . September 10, 1981.
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HP-2-501, " Verification of Calibration of the Victoreen Condenser . R-Meter and R-Chamber," Revision 1, February 5, 1982.
HP-2-409, " Calibration of the Eberline R0-2 and R0-2A," Revision 0, . December 9, 1981.
, HP-2-437, " Calibration of the DCA Area Alarm Monitor 3090," . Revision 0, March 9, 1982.
Findings: The above procedures reference nonapproved support . procedures.
Calibration instructions do not provide for a distance between the effective center of the source and the effective center of the radiation detector, of seven times the maximum dimension of the source or detector, whichever is larger, as recommended in ANSI N323-1978.
See Section 13 of this report for further discussion on the calibration program.
HP-2-408, " Calibration of the Ludlum 177," Revision 0, December 11, . 1981.
HP-2-412, " Calibration of the Ludlum 12," Revision 0, January 7, . 1982.
, Findings: The above procedures reference nonapproved support procedures.
Both procedures provide only for electrical cali-bration of the instruments and do not include detector calibration.
See discussion in Section 13 of this report.
' HP-2-600, " Control of Respiratory Protection Equipment," . Revision 0, August 10, 1981.
HP-2-625, " Quantitative Testing of Respirator Users," Revision 0, . December 11, 1981.
Findings: These procedures each.contain a different respirator qualification card and different information as to approved respiratory devices and protection factors.
Both items appear ! not to comply with Regulatory Guide 8.15 requirements.
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- . . HP-2-700, " Laundry Handling and Monitoring," Revision 0, August 12, . 1981.
Findings: Procedure references nonapproved support procedures.
Also, the procedure does not provide adequate instructions on maximum radiation levels of laundry to preclude unnecessary exposure to personnel during sorting and handling activities. The inspectors noted that personnel are allowed to wear contaminated (approximately 50,000 dpm or greater) ' protective clothing in contact with their body when personnel are considered radioactively contaminated, in accordance with a station directive, at 500 dpm. This procedure does not provide any monitoring or contamination limits for alpha activity.
HP-2-702, " Decontamination of Tools, Equipment and Areas," . Revision 0, December 9, 1981.
Findings: Procedure references nonapproved support procedures.
Also, the procedure does not provide for evaluation of decontamination methods based on: contamination levels, radionuclides present, or how contamination is affixed , to an item. The procedure should provide a decontamination form to be used in accounting for each item being decontaminated, specifying special decontamination methods, and tracking the effectiveness of each decontamination cycle.
, " This procedure references use of HEPA-filtered vacuums, but no station procedures for assembly and testing of HEPA-filtered vacuums are referenced.
HP-2-801, " Removal of Material and Equipment from a Radiation . Controlled Area," Revision 1, September 28, 1981.
Findings: Procedure references nonapproved support-procedures. Also, insufficient instructions are provided to prevent the release of materials with contamination exceeding established station limits residing in areas not readily surveyable. Furthermore, this procedure uses several contamination limits for beta gamma activity that are not consistent, such as release of items by frisking at 50 cpm / probe and 500 cpm / probe.
' HP-2-806, " Leak Test of Sealed Sources." Revision 1, January 22, . 1982.
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, Findings: Procedure references nonapproved support procedures.
The allowed loose contamination limits on seal sources (less then 11,100 dpm) are not consistent with licensee's limits for clean work areas (less than 500 dpm beta gamma and 50 dpm alpha activity) established by other plant procedures.
Also, different requirements for leak testing alpha sources exist.
Procedure HP-2-805, " Radioactive Material Accountability," only requires leak testing of alpha sources containing greater than 10 microcuries of radioactivity and this procedure has 5 microcuries as the exemption limit.
HP-2-812, " Receipt of Radioactive Material," Revision 0, . December 9, 1981.
Finding: Procedure references nonapproved support procedures.
Also, no indication is given as to whether alpha or beta gamma contamination is the major concern.
The loose surface contamin-ation limits allowed are not consistent with surface contamination limits established in other station procedures or HP Group Directive 82-02, as it applies to clean areas.
HP-2-813, " Radioactive Waste Handling," Revision 1, October 6, . 1981.
Findings: Procedure references nonapproved support procedures.
The procedure does not contain sufficient information to ensure requirements are met for external loose surface contamination, external radiation, and proper labeling of containers.
c.
Planned / Scheduled Procedures HP-1-100, " Health Physics Manual."
. HP-1-101, "ALARA Program Implementation."
. HP-1-107, "High Radiation Area and Locked High Radiation Area . Access Control."
HP-1-110, " Radiation Work Permits."
. HP-1-113, " Control of Radiography Operations."
. . HP-1-151, "Use of Self-Reading Pocket Dosimeters" revision to HP-2-102.
HP-1-203, "ALARA Committee Operation."
. HP-1-204, "ALARA Cost-Benefit Evaluation."
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. . HP-1-213, " Control of Reactor Building Power Entries."
. HP-1-214, "RCA Control Point Operation."
. \\ HP-1-215, "NRC Radiological Reporting Requirements."
. HP-1-217, " Health Physics Personnel Qualification Program."
. HP-1-230, "Offsite Dose Calculation Manual."
. HP-2-304, " Operation of the Eberline PRS-2/NRD."
. HP-2-313, " Operation of the Reuter Stokes Pressurized Ion . Chamber."
HP-2-325, " Operation of the NMC Continuous Air Monitor."
. HP-2-333, " Operation of the Ludlum Scaler 2000."
. ! HP-2-334, " Operation of the Ludlum Model 2218 Dual Stabilized . j Analyzer."
HP-2-350, " Operation of the Whole Body Counter."
. HP-2-351, " Operation of the Panasonic Automatic TLD Reader . ] VD-710A."
HP-2-352, " Operation of the GeLi System."
. HP-2-353, " Operation of the Panasonic Manual TLD Reader VD-702E."
. t l HP-2-360, " Operation of the Radiation Monitoring System Console."
. ' HP-2-414, " Calibration of the Ludlum 12s."
. , HP-2-425, " Calibration of the NMC Continuous Air Monitor."
j . l l HP-2-426, " Calibration of the Eberline AMS-3."
. ! , HP-2-430, " Calibration of the Eberline SPA-1 with the MS-2."
. HP-2-441, " Calibration Operational Check of the IRT Portal , . l Monitor."
! ( HP-2-450, " Calibration of the Whole Body Counter."
. HP-2-451, " Calibration of the Panasonic Automatic TLD Reader . VD-710A."
HP-2-452, " Calibration of the GeLi System."
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. , HP-2-453, " Calibration of the Panasonic Manual TLD Reader VD-702E."
. HP-2-471, " Calibration of Air Sampler Flow Meters, H-809c and i . H-809V."
! HP-2-472, " Calibration of the Eberline RAS-1."
. HP-2-602, " Respiratory Protection Equipment Quality Assurance ! . Program."
HP-2-627, " Operation of the Respirator and Filter Check Station."
. L HP-2-631, Filling Self-Contained Breathing Apparatus Bottles."
! . HP-2-637, " Verification of Minimum Airflow in Respiratory ' . Protective Devices."
HP-2-704, " Personnel Decontamination."
. This item is considered open (82-04/18) pending: Licensee evaluation of findings presented in Section 17.b of this . report.
Completion of procedures referenced in Section 17.c of this i . report.
18.
Exit Interview The inspectors met with licensee representatives, identified in Section 1,
at the conclusion of the inspection on March 5, 1982.
The inspectors discussed the scope and findings of the inspection.
The inspectors ' stated that the open items identified in the report must be resolved before issuance of an operating license.
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