IR 05000409/1980010
| ML19345H154 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 02/24/1981 |
| From: | Carbaugh E, Fisher W, Grant W, Greger L, Wehmann G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19345H150 | List: |
| References | |
| 50-409-80-10, NUDOCS 8105010067 | |
| Download: ML19345H154 (34) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-409/80-10 Docket No. 50-409 License No. DPR-45 Licensee: Dairyland Power Cooperative 2615 East Avenue - South Lacrosse, WI 54601 Facility Name:
Lacrosse Boiling Water heactor Appraisal At:
Lacrosse Boiling Water Reactor Site, Genoa, WI Appraisal Conducted:
September 22 - October 3, 1980
&Gfcu Team Members:
L. R. Greger, NRC 2/W///
M. 4 ). A e a/z</rj W. B. Grant, NRC hxf?
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E. H. Carbaugh, Battelle Laboratories AcQ-
g, G.Wehmann,yn
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Consultant Approved By:
W. f.. Fis er, Chief J2/2y/Pf_
Technical Inspection Branch
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Appraisal Summary:
Ay raisal on September 22 - October 3, 1980 (Report No. 50-409/80-10)
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Areas Inspected: Special, announced appraisal of health physics program,
including organization and management, qualifications, training, internal and l
external exposure controls, surveillance, access controls, instrumentation,
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ALARA, radioactive waste, facilities and equipment, and accident response.
The appraisal involved approximately 370 man-hours onsite by four inspectors.
Results: Several significant weaknesses in the health physics program were
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identified in the areas of organization and management (Section 3), training (Section 4), procedures (Section 6), exposure controls (Section 7), surveys (Section 8), instrumentation (Section 9), and ALARA (Section 10). Three apparent items of noncompliance were found (Level V violation - inadequate radiation survey - Section 8; Level V violation - failure to follow procedures - Section 6; Level VI violation - failure to make timely submittal of semiannual effluent reports - Section 3).
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DETAILS 1.
Persons Contacted G. Boyd, Operations Supervisor R. Brimer, Instrument Engineer P. Gray, Mechanical Maintenance Supervisor
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G. Joseph, Security Director
- L. Kelley, Assistant to the Operations Supervisor
- L. Krajewski, Health and Safety Supervisor P. Moon, Shift Supervisor W. Nowicki, Instrument and Electrical Supervisor
- J. Parkyn, Assistant Plant Superintendent M. Pcisean, Shift Supervisor
- P. Shafer, Radiation Protection Engineer
- R. Shimshak, Plant Superintendent
- T. Steele, Director of Environmental Affairs
- J. Taylor, Assistant General Manager for Power M. Branch, NRC Resident Inspector
- W. Forney, NRC Senior Resident Inspector The inspectors also contacted other licensee employees, including members of the technical and engineering staffs.
- Denotes those attending the exit meeting.
In addition, Messrs. W. L. Fisher and K. hidgway from NRC Region III attended the exit meeting.
2.
General This special appraisal, which began at 8:00 a.m. on September 22, 1980, was conducted to evaluate the adequacy and effectiveness of the licensee's overall health physics program. The Appraisal Team consisted of two in-spectors from the NRC Region III office and two contractor personnel.
General tours and examinations of licensee facilities were conducted on September 22 and 23, 1980. Selected licensee facilities were examined in more detail during the remainder of the appraisal period.
Independent direct radiation and contamination measurements were made by the Appraisal Team.
The scope of the appraisal included the health physics organization, management controls, qualifications and training of health physics personnel, training of cadiation workers, radiation protection program implementation, radioactive waste processing, effluent controls, and the chemistry and counting laboratories. The licensee's past and anticipated future perform-ance under both routine and abnormal conditions was examined.
Significant weaknesses were identified in several areas of the licensee's health physics program, including: organization and management, training and retraining programs for health physics personnel, procedure coverage-2-
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and adherence, internal and external exposure control programs, the radia-tion surveillance program, certain instrumentation practices, and ALARA activities.
Lesser program weaknesses are identified in the report. Some of the identified weaknesses are expected to have a greater effect upon the licensee's ability to cope with radiation conditions encountered during and after significant reactor accidents than those encountered during normal operations.
Because significant problems may not have been encountered in the past does not ensure that problems would not be encountered in signifi *
cant abnormal situations.
The licensee's performance in the health physics area was noted to have improved over the last few years. Additional improvements, in the areas noted in this report, are considered essential to the continued upgrading of radiation protection activities.
3.
Organization, Management, and Qualifications
Organizational Structure The licensee's heal'.h physics organization is directed by.the Radiation Protection Engineer, who reports directly to the Plant Superintendent. Radiation safety and chemistry functions are com-bined under the Radiation Protection Engineer and one supervisor (Health and Safety Supervisor), who directs the activities of the seven health physics technicians. The health physics technicians provide shift coverage for radiation protection and chemistry activities. There is minimal specialization among the technicians.
The lack of specialization appears to have evolved because of the small plant and health physics staff size. Continuity within the radiation protection and chemistry job functions may be improved if two recently promoted Senior Health Physics Technicians are assigned coordination duties for these job functions as discussed by the Health and Safety Supervisor.
As noted in previous NRC inspection reports, the licensee's technical exper}jseinthehealthphysicsareahasbeenconsideredweakinthe past.- The continued need for improvement in this area is evidenced by recent problems regarding:
(1) high range noble gas monitoring (Section 9.e), (2) the SAM charcoal analysis procedure (Section 11.a),
(3) the isokinetic stack sampling system (Section 11.a), and (4) the oil storage room noble gas release quantification (Section 11.a),
among others. The addition of a Radiation Protection Engineer position in 1978 attempted to correct this situation. The first individual hired to fill the 3adiation Protection Engineer position functioned as a staff engineer rather than as manager of the health physics program, i
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1/ IE Inspection Reports 50-409/78-17, 50-409/77-23, and 50-409/77-03.
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as had been intended originally, due primarily to his lack of plant experience. The present Radiation Protection Engineer, who was hired in June 1980, was recently put in charge of the health physics program.
Before this, the Health and Safety Supervisor had reported directly to the Plant Superintendent. Although the health physics managerial organization appears to have been strengthened by the recent change, the Radiation Protection Engineer has retained a con-siderable workload from his staff position, principally the emergency plan revision. This workload detracts from his ability to fulfill his managerial role. This and other such assignments would normally be given to corporate or plant staf f engineers, but due to plant staf f size, such assistance is not available. The Appraisal Team believes that the Radiation Protection Engineer should be allowed to devote the majority of his time to his health physics managerial function.
This situation has been exacerbated since the onsite partion of the appraisal by the loss of the Health and Safety Supervisor. The Appraisal Team believes that immediate compensatory actions by the licensee are needed to prevent deterioration of the health physics program due to this loss.
l Based on the appraisal findings, the licensee needs additional improvement in resolving technical problems affecting the health physics program to achieve an acceptable program. The needed improvements may be effected by improved allocation of present management personnel. With the recent loss of the Health and Safety Supervisor, prompt corrective actions are necessary to strengthen the health physics management staffing.
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tion, permanent assignment of technician (s) to chemistry and to-radiation protection specialities should be considered for im-provement. This may be accomplished by use of the Senior Health Physics Technicians to provide coordination for these activities.
b.
Staffing and Qualifications Health physics technician continuity has been fairly good. The seven current technicians average more than five years with the licensee. The current health physics technician staffing level of seven reflects an increase of three over the last ten years.
Health physics management staffing has increased by one over the same time period. The staffing increases may not have been entirely adequate to keep pace with the health physics needs, however. As noted in the previous section, the licensee's technical health physics capabilities have appeared to need upgrading for several years. An additional health physics management position was added in 1978, but the technical workload, especially the post-TMI upgrade requirements imposed by the NRC, have increased to the point where both of the health physics management personnel appear overworked.
Health physics technician staffing also appears marginal for the current workload. Technician staffing appears adequate for routine
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operations but somewhat strained during periods of heavy workload such as outages or extended absenteeism. The need for additional training for technicians (see Section 4) will add to the workload problems. The Appraisal Team believes that the licensee should evaluate the need for additional personnel or workload changes within the health physics group to improve personnel effectiveness.
Current health physics personnel meet or exceed the ANSI N18.1-1971 selection criteria for their assignments.
An initial trainee program of at least one year is utilized to orient new technicians. This phase may be extended based upon previous experience and orientation progress as subjectively determined by the Health and Safety Supervisor.
No health physics technicians with less than two years experience were assigned to shift work. Documentation exists to show that the shift health physics technicians meet the criteria specified in the March 15, 1977, letter from NRR clarifying the technical specification requirement to have an individual qualified in radiation protection procedures onsite when fuel is in the reactor. A shortcoming in this area is the lack of formal procedures which would define selection and qualification requirements for the various positions within the health physics group.
Based on the appraisal findings, increased health physics staffing or better allocation of present staffing is needed to achieve an acceptable program in this area.
In addition, the following item should be considered for improvement: select _*on and qualification requirements for health physics positions should be formalized and should incorporate the ANSI N18.1-1971 guidance.
c.
Authority / Communications / Performance Although the health physics group has formally defined authority over radiation protection matters, the radiation protection program is run less forcefully and formally than is desirable in the Appraisal Team's opinion. While the general attitude of plant personnel re-garding radiation protection appears positive, there are certain radiation protection practices which are not consistently followed by plant workers (e.g., personal frisking). Such shortcomings do not appear to have been addressed sufficiently by the health physics group in the past. A radiation occurrence report system is quite beneficial in identifying problems with radiation protection prac-tices and personnel adherence to these practices.
Such a system is not utilized by the licensee to document problems and their corrective actions nor does strong disciplinary action appear to be taken in response to radiation protection infractions. These infractions appear to be tolerated as long as significant radiation exposures t
do not result. There are indications that the current Radiation Protection Engineer, who assumed responsibility for managing the health physics group recently, may improve the control exercised by the health physics group.
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Improvement in the performance of the health physics technicians appears desirable.
Greater inquisitiveness and responsibility appear needed.
In several instances, their performance did not appear sufficiently responsive to anomalous situations, as noted in
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the following examples. When a monitor sample pump was replaced with a different type pump recently, the significance of the result-ing flow change on the sample representativeness (isokinetic flow)
was not questioned, although the technicians routinely recorded the flow rate.
(Section 11.a) Several radwaste containers were recently relocated within the radwaste building by health physics technicians without adequately considering the effect of such movement on radiation levels outside of the building.
(Section 8.a)
Several unposted radiation hot spots, identified in the contairaent and turbine buildings by NRC inspectors on two occasions recent?y, had gone undetected by the health physics technicians.
(Section 8.a)
A liquid calibration technique was altered by a health physics technician recently such that instead of diluting the calibration liquid for a multipoint calibration, the nuclide ratios were varied, thereby introducing an unwanted variable due to differential energy response of the monitor. These items indicate a need for improved training and management of the health physics technicians.
Morale within the health physics group and plant staff in general appeared good.
Communications within the health physics group also appeared good, although the health physics log could be used to better advantage. Members of the maintenance group expressed concern over certain radiation protection matters, principally their radiation exposures. These concerns appear to have resulted from insufficient communication rather than actual radiation protection problems.
Based on the appraisal findings, stronger management control over the plant radiation protection program and improved health physics technician performance appear needed to achieve an acceptable program in this area. The use of a radiation occurrence record system should be considered to document radiation protection problems and corrective actions.
d.
Corporate Support Corporate involvement in the licensee's health physics program is quite limited. The major corporate involvement appears to be com-pilation of the semiannual radioactive effluent report. These reports, which are due within 60 days after January I and July 1 of each year, have not been submitted on time since the first half of 1977. The five most recent reports submitted ranged from one week late to two months late. The report for the first six months of 1980, due August 30, 1980, had not been submitted as of January 9, 1981. Failure to submit these reports within the 60-day time period represents noncompliance with Technical Specification 3.9.3(a).
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l Although a certified health physicist (ABHP) is on the corporate staff, he apparently has not been significantly involved in the plant health physics program for several years. Health Physics activities (e.g., technical studies and long range planning) which are commonly-handled by corporate staffs are handled instead by consultant personnel or plant personnel, as time permits. As noted in this report, improvements appear needed in several areas of the health physics program (e.g., technical support, ALARA program, and technician training program). A principal obstacle to be overcome to effect these improvements appears to be one of manpower availability, whether on the corporate or plant levels. Finanacial support for the plant health physics program has been limited in the past but may be improving as evidenced by recent or planned appropriations for the hiring of an experienced Radiation Protection Engineer and for equip-ment acquisitions.
Based on the appraisal findings, improved technical support for the health physics program is needed. This support may be provided from the corporate structure, outside consultants, or plant personnel.
Additionally, timelier effluent report issuance is needed to comply with regulatory requirements.
4.
Training The licensee's training program includes initial training and refresher training in radiation safety for general workers and specific work groups.
Radiation training provided per 10 CFR 19.12 appeared adequate. The training program for health physics personnel, however, was not fully acceptable.
a.
Health Physics Technician Training New health physics technicians receive the routine plant employee radiation safety indoctrination and then serve as trainees until the Health and Safety Supervisor determines that the individual is qualified. The trainee phase typically lasts one year, although it has lasted greater than three years. Although the Health and Safety Supervisor appeared to place adequate demands upon trainees, there are no formal training criteria, practical factor requirements, or testing to define the training program and to judge adequate comple-tion of the trainee phase. The Appraisal Team believes these items are essential to the conduct of a consistent training program and should be developed. The licensee does not define formal refresher training requirements for health physics technicians. Some offsite training has been utilized for health physics technicians in the past but such training has not been part of an organized program.
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The Appraisal Team believes that an effective technician training program is essential to a successful health physics program. A
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health physics technician training program, including refresher training, must be developed and implemented as soon as possible.
The initial training requirements should be sufficient to document qualification as a " responsible" technician per ANSI N18.1-1971 and provide a basis for determining those activities which other technicians can perform without supervision.
Additional improvements needed in the health physics technician training program are:
(1) inclusion of plant systems training, (2) conduct of " hands-on" training on emergency sample collection and analysis, and (3) establishment of a training commitment as a fraction of available technician time. The latter is important to prevent subordination of training needs to more immediately productive activities.
Based on the appraisal findings, development and implementation of a formal training program for health physics personnel is required to achieve a fully acceptable program. The items noted above should be considered for inclusion in the training program.
b.
10 CFR 19.12 Training Training required by 10 CFR 19.12 for individuals frequenting re-stricted areas is administered by the Health and Safety Department.
The majority of this training has been given personally by the Health and Safety Supervisor. Sufficient guidance and documentation exists to ensure consistency for the training. An abbreviated version of the training is given escorted visitors. Although testing normally is not used in conjunction with the training, the format allows ade-quate appraisal of the trainee's knowledge. The training format and content is very effective, especially for the limited number of individuals processed at the plant. However, the time needed to cen-duct the training is somewhat of a burden on the Health and Safety Supervisor. Two recently promoted Senior Health Physics Technicians could conduct this training.
Based on the appraisal findings, this portion of the licensee's program appears to be acceptable.
c.
Other Training Refresher radiological safety training is given all plant radiation workers annually. A refresher training session attended by appraisal team personnel was adequate, the Health and Safety Supervisor con-ducted the session. Additional radiological protection training is received in safety meetings and pre-outage meetings.
Licensed operators receive additional radiation protection training in their requalifica-tion program. These training programs were cursorily reviewed; no problems were noted.
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Although radiation protection training for non-health physics personnel appeared adequate on paper, numerous infractions of radiation protection procedures and practices were observed by the appraisal team members and the resident NRC inspectors.
These infractions appear indicative of a need for improved radia-tion protection training. The need for improved radiation protec-tion training was further discerned from concerns expressed by several members of the maintenance group.
These concerns appeared founded more on lack of information than on actual radiatior protection problems.
Based on the appraisal findings, this portion of the licensee's program appears to be generally acceptable; however, the need for additional radiation protection training of non-health physics personnel should be evaluated.
5.
Quality Assurance The Quality Assurance Department's involvement in the health physics program includes review and approval of procedures and certain other documents, and performance of a routine administrative audit program.
No specific problems were noted regarding the review and approval function; however, improvement in the auditing function appears desirable.
The QA Department reviews all Health and Safety Department procedures, administrative control direct'.ves, plant Operating Manual sections, purchase requisitions, and chemistry reports for compliance with format, content, and quality assurance program requirements. This review constitutes an administrative review only, with reliance placed on the Health and Safety Department for definition of appropriate quality requirements. No problem was noted with this system.
The QA Department performs routine administrative audits (i.e., conform-ance to procedural requirements) of the health physics program. Audits are scheduled such that the health physics program is completely audited biennially. Audits are performed according to preplanned checklists; results are reported to Health and Safety Department management and the Plant Superintendent. While the scope of audits appeared to be adequate, increased auditing of procedure adherence appears warrante based on the Appraisal Team's findings.
(See Section 6.) Although outside technical consultants have been utilized in some QA audits, there apparently is no formal policy regarding such use and there are no immediate plans to use technical consultants for future audits.
In addition to the QA Department administrative audits, the plant Safety Review Committee performed a technical and administrative audit in 1979 utilizing an outside consultant. This audit appeared adequate in scope and detail. A number of the recommendations made by the auditors were implemented by the licensee. The Appraisal Team noted, however, that-9-
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some of the problems identified during the audit still existed, notably lack of a technician training pr gram and a heavy clerical / administrative workload on the Health and Safety Supervisor (See Sections 3 and 7.)
Based on the appraisal findings, the licensee appears to have adequate Quality Assurance Department participation in the health physics program.
This program could be improved, however, by better auditing of procedure adherence.
6.
Procedures Radiation protection procedures appear in Volume X of the LACBWR Operating Manual, the Administrative Control Directives (ACD's), and Health and Safety Department (H&S) procedures. Additional guidance is provided in H&S memoranda, vendor equipment instruction manuals, and informal (un-approved, uncontrolled) department procedures.
Individual procedures were reviewed by the Appraisal Team as they pertained to areas examined during the appraisal; comments on specific procedures are included in other sections of this report. Although the administrative review, approval, and change system was acceptable, problems were identified concerning adherence to approved procedures, utilization of the temporary change system, and the existence of approved procedures for some activities.
Licensee performance in this area appeared to indicate an overly lax atti-tude toward procedure use.
The licensee has an acceptable process for procedure review, approval, issue, and change, including a requirement for biennial review of all existing procedures. Radiation protection procedures receive both technical and administrative reviews. Revisions and changes to pro-cedures receive the same review as the initial procedure. Health and Safety Department management approval is equired.
A temporary change may be effected with approval by two Lembers of the plant management staff (including one holder of a senior reactor operator's license.) Temporary changes expire in ten days unless approved by the Plant Superintendent and the Operating Review Committee. A formal distribution system exists for controlled copies of procedures, but temporary changes are maintained in the control room and not distributed.
A weakness of this system is that individuals using controlled procedures may not know that a temporary change has been made to a procedure unless they check with the control room. According to licensee personnel, no problems have been experienced resulting from this weakness.
Adherence to approved procedures is required by Technical Specifications 3.8.1 and 3.11.
Contrary to this, the Appraisal Team found several instances where approved procedures were not followed routinely. These are documented in Sections 8, 9, and 11 of this report. Several plant personnel stated that strict adherence to procedures was not required as long as the intent of the procedure was not violated.
If allowed to exist, this attitude can lead to a lack of general confidence in pro-
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cedures and inconsistency in job performance.
Several technicians also were unaware of the temporary change system. This could result in not keeping procedures current, thereby further degrading procedure useful-ners.
Improved licensee attention to requirements for procedure adherence is necessary. Procedures must be kept current to be useable.
Approved procedures appear required for some tasks not presently-covered by procedures. These tasks include external dosimetry review and evalua-tion, primary calibration of the whole body counter, double step-off pad usage, and survey instrument usage and calibration.
Further details for these items are included in Sections 7, 8, and 9.
The planned delegation of some of the above tasks to technicians increases concerns that approved procedures be established. While the existence of procedures does not ensure adherence, it does ensure responsible review of performance and acceptance criteria and enhances consistency, especially if more than one worker is involved.
One area of concern occurs when two or more acceptable methods which are not compatible exist to execute a task. Such a situation was observed regarding the use of double step-off pads.
One method called for donning shoe covers at the first step-off pad, then changing shoe covers at the second step-off pad. A second method was to don rubber shoe covers over cloth shoe covers which were donned at the first step-off pad, when the second step-off pad was crossed.
In the former case, the inside of the shoe covers should be radiologically clean, but in the latter, the inside would be potentially contaminated.
Individually, each of the methods is acceptable, but jointly they are incompatible.
Procedures must be established under such circumstances to define accept-able methods.
Some management personnel interviewed indicated a preference to place emphasis on professional judgment and training to accomplish radiation protection program goals and considered formal procedures a hindrance to efficient plant operations and a potential trap for NRC citations.
Contrary to this, well written procedures should augment professional judgment and training by defining acceptable methods and providing acceptance criteria to workers.
Such procedures need not be grossly detailed " cook book" approaches to activities. Guidance for procedure preparation and activities which should be covered by procedure is included in ANSI N18.7-1976 and Regulatory Guide 1.3.
Based on th-appraisal findings, improved adherence to procedures and the establishment of approved procedures for additional activities appear needed to achieve a fully acceptable program.
7.
Exposure Controls and Dosimetry The licensee's external and internal radiation exposure control and dosimetry programs were reviewed for scope, content, performance, and
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adequacy.
While the programs have apparently functioned acceptably in the past, several weaknesses appear to exist, and improvements are needed to achieve a fully acceptable program.
i a.
External Exposure Control and Dosimetry Ext tal radiation exposures are monitored by a combination of thermoluminescent dosimeters (TLD's), self-reading pocket ion chamber dosimeters, and neutron dose rate measurements coupled with time keeping. Administrative controls appear to have been effective in limiting personal exposures. Needed improvements include establishment of TLD spiking and TLD/ pocket dosimeter intercomparison programs. Additional desirable improvements are noted below.
The if censee utilizes a contract TLD service. Two TLD-100 lithium fluoride chips are used per badge for whole body and skin dose assessment. Quantities of TLD's available appeared adequate, with
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approximately 110 badges issued per month and 40 available as spares.
Assigned dosimetry is stored at the plant guardhouse and is issued upon entry to the restricted area.
Spare dosimeters are stored in the administration building envircamental lab. Control dosimeters are kept at both storage locations.
Dosimetry reports are received from the vendor approximately two weeks after the monthly badge changeouts. Provisions exist for expedited handling (24-48 hours)
for suspected high exposures. Extremity monitoring is performed when necessary, using additional TLD badges taped to the extremities.
This practice is acceptable, but the use of finger ring TLD's would improve dexterity and convenierce for hand / finger monitoring, and may allow closer positioning of the TLD to the radiation source.
Self-reading pocket dosimeters are used to monitor exposures on a short-term basis. Health physics technicians read pocket dosimeters daily during the night shift, logging results and rezeroing as re-quired.
In addition, individuals are instructed to have dosimeters rezeroed when approximately 100 mrem has been accumulated. Entry and exit dosimeter readings are required to be logged on RWP's.
Pocket dosimeters are tested for accuracy and drif t consistent with ANSI'N13.5-1972 and Regulatory Guide 8.4.
Procedure HSP 10.1 details these tests but does not specif y a performance frequency; testing has occurred approximately semiannually per Regulatory Guide 8.4 recommendations. Quantities of dosimeters appeared adequate (250 low range and 150 medium and high range).
Neutron dose assessment is performed by time keeping. Dose rates are measured monthly during routine radiation surveys, using a rem-meter, and are supplemented with job specific surveys as necessary. Neutron doses have been determined for several routine tasks (tours, surveys, sampling), based an experience. Typical neutron doses to personnel
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were less than 100 mrem per quarter with a maximum of 200 mrem per quarter observed for one individual. No problems were noted with the application or use of neutron dosimetry.
Emergency kits contained low and high range pocket dosimeters but did not include TLD's.
In the event of evacuation, Health and Safety Department management personnel intend to bring spare TLD's from the environmental lab storage location to the evacuation point.
A better arrangement would be to include TLD's in each emergency kit to minimize the tasks required as part of an evacuation.
Daily, quarterly, and annual administrative limits are used. While no special administrative limits are imposed upon female employees, Regulatory Guide 8.13 is reviewed with them, and they may voluntarily limit their dose to the Regulatory Guide recommendations. An alert system provides documented H&S Supervisor review and approval to exceed administrative limits, and notification to work group supervi-sion when administrative limits are approached. Monthly dose summaries are provided to plant supervision.
These exposure controls appear to have functioned well over the last few years, as evidenced by only six individuals exceeding the five rem per year administrative limit since 1973.
The licensee's personal dose records are compiled mar.ually by the H&S Supervisor. This appeared to place an unnecessary administrative workload on that individual; the task could easily be delegated to clerical personnel. Delegation of this and similar activities would allow the H&S Supervisor to perform more technical and supervisory work. The Appraisal Team reviewed random and selected personal dose records; no problems were identified.
Quality assurance provisions for the external exposure control program appeared weak. While TLD spiking has been performed intermittently in the past (most recently about two years ago), there is no routine program for submittal of spiked TLD's.
Spiking TLD's provides routine surveillance of vendor performance, allowing intercomparison with calculated or measured standards.
Spiking should be conducted on a planned and periodic (e.g., quarterly) basis. Monthly TLD result are compared regularly with pocket dosimeter records; however, there are no formal acceptance criteria or procedures for the comparisons.
Acceptance criteria and follow-up actions are left to the professional judgment of the evaluator. Such informality does not ensure consistent evaluations. A formal procedure is needed for this task.
Additional improvement could be effected in the external exposure control program through development of formal procedures for maintenance of neutron stay time and dose legs and record retention practices.
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Based on the appraisal findings, formalized TLD spiking and TLD/ pocket dosimeter intercomparison programs are needed to achieve a fully acceptable external exposure control program.
In addition, the following improvements should be considered:
(1) use finger ring TLD's for extremity monitoring, (2) specify frequency for pocket dosimeter testing in procedure HSP 10.1, (3) provide TLD's in emergency kits, (4) delegate record keeping duties to clerical personnel, and (5) develop procedures for maintenance of neutron stay time and dose logs and for record retention.
b.
Internal Exposure Control and Dosimetry Internal exposure controls include engineering controls, such as ventilation and area / equipment decontamination; an air sampling program; an MPC-hours log; approved respiratory equipment; a bioassay program (whole body counting) to monitor effectiveness of other controls. These controls appear to have been effective in minimizing internal exposures; however, additional respirators
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appear needed for accident response. Additional desirable improve-ments in the routine program are discussed below.
Engineered controls and air sampling / monitoring practices are dis-cussed elsewhere in this report.
(Section 8, 9, 10) Charcoal cartridges are not used routinely for iodine collection.
Instead, charcoal impregnated particulate filters are counted for radioiodines in addition to particulates.
Plant comparisons showed that the par-ticulate filter iodine collection efficiency is approximately 50%.
The filters are used as gross indicators; charcoal cartridges are used when iodine is identified or suspected. Whole body counting and effluent iodine sampling provide additional information re-garding possible iodine exposure.
An MPC-hours log is maintained; exposures greater than two MPC-hours / day or ten MPC-hours / week are recorded in workers' per-manent files. Administrative MPC-hour limits (8/ day, 40/wk) have been established for limiting personnel access or requiring respiratory protection. Review of the MPC-hours log showed few
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workers with exposures in excess of the two and ten MPC-hour thresholds. The effective use of an MPC-hours log can reduce
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whole body exposures by allowing workers to work more efficiently (free of respirator interference) in areas of low airborne con-tamination but significant external radiation fields.
No problems were noted with the licensee's use of the MPC-hours log.
The licensee recently implemented a formal respiratory protection program in accordance with Regulatory Guide 8.15 requirements.
Plant policy requires respirator use when administrative limits (8 MPC-hours / day or 40 MPC-hours / week) would be exceeded without such use. The plant has 13 NIOSH approved full-face air purifying
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masks, 15 air line hoods, and 11 pressure demand self-contained breathing units (SCBA). Quantities of respirators appeared adequate for routine plant operations but inadequate for emergency response, especially intermediate and long-term response. Several dozen air purifying masks lacking NIOSH approval have been removed from service and placed in storage. The licensee indicated these masks would be used in an emergency, although no credit would be taken for protection factors. The Appraisal Tean believes that additional NIOSH approved respirators should be procured, or documented arrange-ments should be made to borrow respirators from another plant in an emergency rather than relying on unapproved respirators. Refill capacity, available from a cascade bottled air system is sufficient to maintain four people in SCBA gear for eight hours (fire protection Technical Specification requirement). Additional SCBA devices and j
refill capability are available at an adjacent licensee-owned facility.
Hood air supply is provided from the plant service / instrument air compressor; a manifold cart provides cleaning, filtering, and carbon monoxide monitoring for the air. Respiratory protection equipment appeared in good condition. All plant personnel (including guards, but excluding secretaries and janitors) have been qualified for t
respirator use.
Qualification includes initial training, annual review and retraining, annual medical certification, and a qualitative fit test using isoamyl acetate performed in open air. A fit test booth, as described in NUREG-0041, would improve the testing method by allowing better simulation of work activities under challenge atmosphere conditions. Procedures covering the respiratory protection program, contained in Volume X of the LACBWR Operating Manual, appeared adequate.
A bioassay program, provided for verification of internal exposure
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control program effectiveness, includes semiannual whole body counting of all plant personnel, entrance and exit counts of selected workers, and investigative counting following suspected internal exposures.
Random and selected personnel files were reviewed; WBC records and results appeared acceptable. Other methods of bioassay have been used in the past (nasal smears, tritium urinalysis, throat smears)
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but are no longer in routine use.
Tritium urinalysis, stopped in 1977 due to chronic negative results, would be reinstated if survey
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results indicate a need according to licensee personnel. The scope of the present bioassay program appears acceptable; however, the Appraisal Team believes that routine nasal smears following respirator use are beneficial for identifying suspected uptakes.
The licensee-designed chair whole body counter (WBC), which utilizes a fixed 3" x 3" NaI detector coupled to a 512 channel multianalyzer,
includes thyroid counting capability. Calibration checks, performed before each use, utilize a mixed gamma source for channel (energy)
calibration and a cesium-137 source to verify detector efficiency.
Background counts are conducted before and after individual counts
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or every four hours during continuous use.
Sugar phantoms, with sources taped to the phantoms, are used for calibration checks.
Internal positioning of the sources in the phantoms would more accurately simulate internal contamination.
Procedure HSP'13.5, which covers use of the WBC and evaluation of the results, appeared adequate.
Counting efficiency was improved recently by adding shielding to the WBC and relocating it to a low-background area in the new administration building. No calibration of the WBC has.been performed since the relocation, however, and previous calibrations (1976, 1978) had utilized informal procedures. The Appraisal Team-believes a calibration is needed periodically (e.g., annually) in
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i accordance with recommendations-contained in ANSI N343-1978 (American National Standard for Internal Dosimetry for Mixed Fission and Activa-tion Products).
Based on the appraisal findings, the following are needed to achieve an acceptable internal exposure control and dosimetry program:
(1)
provision for additional NIOSH approved respirators for emergency response, and (2) calibration of the whole body counter.
In addition, the following improvements should be censidered:
(1) use of a respi-
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rator fit test booth, (2) conduct of routine nasal smears following respirator use, (3) placing WBC calibration sources inside phantoms rather than on their surface, and (4) use of routine charcoal cartridge rather than treated filter paper sampling for iodine.
8.
Surveillance and Access Control The licensee's radiological control program was examined, including access controls, radiation work permits, and routine and job specific radiation / contamination surveys. The access control review included:
restricted areas, controlled areas, radiation areas, high radiation areas, contamination areas, and radioactive material areas.
Several problems requiring resolution were identified in the access control and routine survey programs. These and additional identified improvements are discussed in detail below.
a.
Access Controls The radiologically restricted portion of the site is within the
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protected area defined for security purposes. All major structures (turbine building, containment building, waste treament building, waste storage area, and warehouses) are within this area. Access to the restricted area is through the guard station located in the administration building. General entry requirements include security badge, pocket dosimeter, TLD badge, and general training in health physics. Access to the restricted areas is further controlled by keycards or. locks. The Health and Safety Department controls the j
keys for the locked restricted areas. Although all areas within
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the protected area fence are not considered radiological restricted areas, access is controlled at this barricade.
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Licensee procedures are not sufficiently clear regarding the dis-tinction between the restricted area and the protected area. The procedures should be revised to reflect actual practice.
The primary access control point for the radiologically controlled areas within the plant is at the entrance to the turbine building from the change room. Lab coats, normally worn within the radio-logically controlled plant creas, are hung in the change area when not being used. Although workers are instructed to change lab coats weekly or sooner if necessary, some lab coats measured as high as 2 mR/hr. The radiation field from the approximately 75 lab coats and a nearby " dirty" clothes bin was sufficient to require the change-room frisker to be set on the X10 scale.
(See Section 9.b) This situation requires correction to ensure that personal contamination monitoring is adequate. Turbine Building access is required to be recorded on a personnel status board located at access control.
The recent use of key cards with computer entry logging may allow discontinuance of the status board, which was not used consistently by workers. As noted in Section 9.b, problems were identified with personal contamination detection practices at the change area.
On several occasions, individuals, including health physics technicians, were observed to bypass one or more of the contamination monitoring instruments in the change area. However, no one was observed to bypass all three monitoring instruments (i.e., frisker, portal monitor, and hand and foot counter).
Radiation area control is provided through area postings and special work permits. The turbine / containment building is posted as a radia-tion area. Radiation surveys conducted by the Appraisal Team identi-fied the following unposted radiation areas:
(1) the ground level of the waste treatment building (general field of 15 mR/hr with hot spots in excess of 100 mR/hr) and (2) outside the northeast corner of the waste treatment building (15 mR/hr at 18 inches from wall). The latter radiation levels were caused by the storage of two 55 gallon drums of waste in the waste treatment building. The drums had been moved to that location approximately five days before the appraisers discovered the external radiation levels. The unposted radiation areas had not been surveyed after movement of the drums. This is in noncompliance with the survey requirements of 10 CFR 20.201(b). The licensee promptly corrected the problem by moving the drums fnto a high radiation area in the basement of the waste treatment bt ilding.
Entry into radiation fields greater than 100 mR/hr, regulated by Operations Manual Section X.27, requires issuance of a Special Work Permit (SWP). Notification of the Control Room before entry and upon exiting high radi. tion areas is required. The Control Room maintains records of the entries. No problems were identified with these controls. The twelve high radiation areas that existed during the appraisal were either locked or alarmed.
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i Contaminated area access is controlled through area postings and use of special work permits. Minimum requirements for entry into posted contamination areas are lab coats, gloves, and shoe covers. Additional protective equipment is specified by the Health and Safety Department as needed. Hard finish (cardboard or plastic) step-off pads are used.
This material appears to be less efficient for collecting and retaining contamination than absorbent or sticky paper pads. Lengthened lifetime was the licensee's reported motive for use of the hard finish pads.
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The licensee generally utilizes radiation ribbon or tape to delineate-
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contamination areas. There were several areas where more complete identification of the area boundary would be desirable.
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The entire containment. building was posted as a contamination area at times during the appraisal. When this occurred, a step-off pad (SOP)
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was placed at the entrance to containment. Additional SOP's were left in place within the containment building. This caused confusion over the correct shoe cover procedure for entry into the local SOP areas.
For lack of official guidance, several different procedures were used initially. The different procedures were in conflict such that foot-wear contamination was likely.
The licensee's procedures for the decontamination of personnel, equipment, and surface areas appeared adequate. Personal decontam-
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ination kits are located at both the north and south emergency j
stations, at the primary access point to the turbine building, and in the waste treatment building.
Licensee personnel reported that
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approximately 40-50 personal contaminations occur per year. These incidents are not routinely documented. The Appraisal Team believes brief documentation of all but the most minor cases of personal-de-
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contamination is desirable, an entry in the health physics log being
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adequate.
Radioactive material is controlled through the use of procedures,
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j postings, and locked storage facilities. A portion of a warehouse has been designated for storage of radioactive material. The licensee uses yellow and white plastic bags interchangeably for both contaminated and noncontaminated material. A better practice would be to distinguish between contaminated and noncontaminated material by bag color differen-l tiation. Other problems noted include:
(1) a vacuum cleaner located l
in the machine shop read 3-4 mR/hr at contact, but was not tagged as being contam;aated internally; and (2) a pipe located on the grade floor i
I of the turbine building was found to be contaminated internally, but was not labelled accordingly.
No posted airborne radioactivity areas were observed during the appraisal. Licensee procedures appeared adequate for control of such areas.
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Based on the appraisal findings, improvements in the following areas are required to achieve a fully acceptable program:
(1) conduct of surveys after operations which are likely to significantly affect radiation levels, and (2) development of a procedure for entering sequential contamination areas.
In addition, the following matters should be considered for improvement:
(1) more-frequent changing of lab coats, (2) use of absorbent or sticky paper step-off pads, (3) documentation of personal contamination incidents, (4) use of radiation tape to identify contaminated area boundaries which are not otherwise identified, (5) use of one color plastic bag for contaminated waste and another color bag for noncontaminated waste, and (6) increased use of internal contamination labels.
b.
Special Work Permits The licensee's special work permit (SWP) program, documented in Volume X of the plant Operating Manual, functions to control work activities in the radiologically posted plant areas. Guidance for SWP preparation appcored adequate. Although the Health and Safety Supervisor approves SWP's, the immediate job supervisor is respons-ible for listing personnel assigned to the SWP and ensuring that each worker has read the SWP and has sufficient dose available.
By initialing the form, each worker signifies his understanding of the requirements of the SWP.
Protective equipment requirements are identified as are the radiation and contamination levels in the work Space for listing special instructions and requirements is area.
provided, including the type of health physics coverage to be provided.
Staytime and radiation dose information is recorded on the SWP by the workers for their entries. The Health and Safety Supervisor maintains man-rem records for each SWP.
After SWP approval, copies are distributed to the Health and Safety Supervisor, the Control Room, the job site, and the job supervisor.
A copy is not posted at access control; such posting appears desirable to inform workers of protective clothing and other requirements while still in the change room.
It would also provide a convenient inf o rmation source for Health and Safety Technicians.
Subsequent changes to SWP's are not entered routinely on all copies. Normally the changes involve adding workers to the SWP. The Health and Safety Supervisor's copy typically was updated to reflect changes made on the job supervisor's and job site copies.
It appears that procedures for making and re-cording changes to SWP's need better definition. As of September 26, a total of 170 SWP's had been issued in 1980. Only three were in effect at the time of the appraisal.
Based on the appraisal findings, this portion of the licensee's program appears generally acceptable. The following matters should be considered for improvement of the program:
(1) define the system for making changes to SWP's such that current informa-
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tion is readily available to workers, supervision, and Health and Safety Technicians, and (2) post current SWP's at access control (change room).
c-Routine and Job Specific Surveys Routine radiation and contamination surveys are conducted at scheduled intervals. Job specific surveys (radiation, contamina-tion, and airborne) are performed as necessary. Problems relating to survey frequencies and procedures are noted below.
Routine direct radiation surveys of the restricted and unrestricted plant areas are nade monthly. Routine alpha, beta, and neutron surveys are made within the containment building only. A radiation survey of the site perimeter is made quarterly. As noted in Section 8.a.,
an unidentified radiation area was found adjacent to the waste treatment building by the appraisers. This area had not been surveyed following transfer of drumnied radwaste within the waste treatment building.
Portions of the radiologically controlled area are not surveyed routinely.
In one such area on the turbine building grade floor (west end), unposted hot spots up to 950 mR/hr were found by the appraisers. The licensee's direct radiation survey program appears to need upgrading in coverage and frequency to enhance identification of radiation hazards.
Plant procedure HSP 2.6.7.11 requires areas with dose rates which exceed the surrounding general area by a factor of three to be posted as hot spots. As noted above, several unposted hot spots were found by the appraisers in the turbine building. Additional unposted hot spots had been identified previously by the resident NRC inspectors in the containment building (IE Inspection Report 50-409/80-11).
In addition to the need for better surveys to identify significant hot spots, procedure HSP 2.6.7.11 appears to need clarification to establish a minimum dose rate below which posting of hot-spots would not be required.
Routine smear surveys are made daily (30 to 70 smears typically) in the restricted areas of the plant and twice weekly in the unrestricted areas. The smears are generally taken from floor surfaces only.
One third of the smears taken by the Appraisal Team on surfaces two to six feet above the floor on the grade level of the turbine building
exceeded the licensee's decontamination level of 2,000 dpm/ft.
In a similar su3vey in the containment building, all 12 smears exceeded 2,000 dpm/ft Floor smears taken by the Appraisal Team confirmed
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the licensee's survey results. The contamination s'urvey program should be expanded to include surfaces other than floors, with which workers are likely to come in contact.
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Routine air samples, taken daily in the containment building and weekly in the turbine building are analyzed for beta gamma and alpha activity. Tritium analysis is performed weekly at six locations.
Airborne iodine sampling frequency appeared adequate. However, procedures do not exist for taking air samples, nor are the results of the routine survey program conveniently posted for use by plant staff.
Based on the appraisal findings, the following improvements are needed to achieve a fully acceptable program in this area:
(1)
The radiation survey program needs review and upgrading to ensure that radiation hazards are_ identified promptly.
Consideration should be given to expanding and increesing the frequency of direct radiation surveys, including surfaces other than floors in con-tamination surveys, and stressing conduct of special surveys following operations which may cause significant changes in radiological conditions.
(2) A procedure should be developed for conducting the air sampling program.
In addition, the follow-ing matters should be considered for improvement of the program:
(1) Establish a minimum dose rate requiring hot spot posting, and (2) Make survey results more readily available to plant workers.
(See Section 12.)
9.
Instrumentation The licensee's supplies, use, maintenance, and calibration of portable and fixed radiation instruments were reviewed. While the licensee appeara to have adequate equipment, supplies, and capabilities, a number of im-provements, noted below, appear necessary for a fully acceptable program.
a.
Portable Survey Instruments The licensee utilizes ion chamber (cutie pie type) instruments for routine beta-gamma dose rate measurements and hardwall probe GM count rate instruments (with beta windows) for gross contamination surveys. The plant maintains nine beta gamma dose rate instruments (including two extendible probe instruments) and four hardwall GM count rate instruments operational for plant use.
Although the plant maintains no formal control over storage or use locations for these instruments, personnel appeared to experience little difficulty in locating instruments and indicated that no significaat shortages had been experienced. Additional instruments include three dose rate and four count rate instruments assigned to emergency kits (located onsite and in Lacrosse), and five dose rate instruments in storage as spares. One emergency kit dose rate instrument was found to be missing a shield over the beta end window thereby ex-posing the mylar window to accidental rupture.
Instruments in service were observed to be in calibration and functional. Survey instrument maintenance and repair turnaround time appeared acceptable.
Overall quantity and condition of instruments also appeared acceptable.
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Special survey instruments include two portable alpha scintillation counters stored in the counting room and three neutron measurement instruments. The neutron instruinents were stored inside the contain-ment building; however, one neutron rem-meter was relocated to the change room during the appraisal.
Instrument quantities and condition were acceptable.
Calibrations are performed semiannually by plant personnel for all instruments except the neutron rem-meters and extendible probe instruments, which receive annual vendor calibrations. Problems identified with the portable survey instrument calibration and func-tional test program include:
(1) Procedure HSP 2.9 specifies calibration of dose rate instruments at multiple points per scale but offers no guidance for point selections; ANSI N323-1978 "Radia-tion Protection Instrumentation Test and Calibration", recommends calibration points at 20 percent and 80 percent full scale. One cutie pie instrument was noted to have single point calibrations on the XI and X10 scales and a two point calibration on the X100 scale.
(2) In several instances, calibration points appeared selected for convenience of source to detector distance measurement rather than dose rate. This practice can introduce unnecessary errors in dose rate scale interpolation, especially with logarithmic scale instru-ments.
(3) The high range cutie pie was not calibrated on the X100 (0-5000 R/hr) scale.
If not calibrated on that scale, it would be-desirable to label the scale "not calibrated." (4) Portable GM count rate instruments receive a single point per scale pulse generator calibration, but no acceptance criteria c.re defined. Response checks to internal reference check sources are performed, but counting.
efficiencies or conversion factors are not labeled on the instruments.
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Nor are the mR/hr scales labeled to warn of the lack of calibration of these scales. At least one technician indicated that the instrument was used for low dose rate ( l mR/hr) surveys.
(5) It was noted that technicians had routinely modified certain calibration data sheets, eliminating the "as found" status, without changing or revising the procedure. As a result, over half of the 1980 calibration records
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did not comply with procedure HSP 2.9 for documenting the "as found" instrument responses.
(6) Instrument functional checks are performed biweekly using internal check sources for GM count rate meters and a fan source for beta gamma dose rate instruments. Response checks to known radiation fields are not normally performed before routine survey instrument use.
Instrument functional checks should be per-formed more frequently for instruments in routine use.
Instrument calibrations (open air) are performed using NBS traceable Calculated source exposure rates are decay corrected at each sources.
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Although source strength is confirmed occasionally with a vendor use.
calibrated survey instrument, use of a condenser R-meter for such confirmation would provide better accuracy. The licensee's condenser R-meter is reportedly defective and has not been used for several years.
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The licensee relies on vendor manuals for instrument use procedures.
This practice is acceptable, but supplemental information is needed regarding instrument limitations due to plant specific practices (e.g.,
high range cutie pie X100 scale not calibrated and mR/hr scale of GM count rate meters not calibrated).
Based on the appraisal findings, the licensee's portable survey instrumentation program appears generally acceptable.
Improvement is desirable, however, in these areas:
(1) performance of response checks before instrument use, (2) indication of instrument scales
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which are not calibrated, (3) improved adherence to procedures, i
(4) program review for inclusion of ANSI N323-1978 recommendations, (5) selection of calibration exposure rates to minimize survey meter readout errors, and (6) periodic verification of calibration source strength using a condenser R-meter.
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b.
Personal Contamination Detection Instruments The licensee uses a combination of friskers, hand and foot counters,
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and portal monitors for detection of personal contamination. Six friskers (three pancake probes and three hardwall probes) are located throughout the plant. These are. supplemented by hand and foot counters at the containment air lock and change room and portal monitors at-
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i the change room and guardhouse. Licensee practice requires use of each instrument type (frisker, hand and foot counter, portal monitor)
present at a control point. Redundant detection capability should not be substituted for conscientious use of the most sensitive in-
strument (i.e., frisking) following work in contamination areas. As noted in Section 8, workers were observed to bypass the friskers in
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favor of the portal monitors or hand and foot monitors on several
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occasions. Plant procedures should be reviewed by the licensee to ensure that personal contamination survey requirements are consistent with the potential for contamination. Additionally, workers should be trained to recognize that significant differences in instrument detection capability exist.
Procedures related to frisking are con-
tained in Volume X of the LACBWR Operating Manual.
Instructions are l
posted at the containment, change room, and guardhouse monitoring l
locations.
However, the posted frisking instructions were not correct
at all locations; a mixup in site unique placards had occurred. This error, which was detected by the Appraisal Team, appears to indicate
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that licensee personnel were not paying sufficient attention to the posted instructions. Although plant procedure HSP 2.8 specifies daily functional checks of friskers, hand and foot counters, and portal monitors with sources and defines adequate acceptance criteria, docu-mentation of these checks was not available. Conversations with i
technicians indicated that in several cases the specified sources were inadequate to provide instrument response. No change or deviation from established procedures to specify alternate check sources had been made. Additionally, friskers required by procedure to alarm at 200 cpm above background were frequently found set at full scale t
(well above the designated set point).
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. The Appraisal Team performed checks with both procedurally specified sources and other licensee sources; the results indicated that pro-cedure acceptance criteria were not always met?* The change room portal monitor _(Eberline PMC-4B)'did not respond at contact to either an 8900 dpm technetium-99 source (specified for use in HSP 2.8) or a 48,000 dpm cesium-137 source. Frame channels of this unit responded to a 220,000 dpm cesium-137 source, though the foot channels did not alarm even with a 400,000 dpm cesium-137 source. Hand and foot monitors were found to meet the acceptance criteria specified in HSP 2.8.
They were capable of detecting and alarming with a 48,000 dpm cesium-137 source. The guardhouse portal monitor (Technical Associates PPM-8) also met the procedural acceptance criteria with detection-capability comparable to the hand and foot counters, although the specified five-second count time was not adequate to consistently initiate an alarm with a 48,000 dpm cesium-137 source.
Increasing the count time to ten seconds should provide additional sensitivity.
In addition, an alarming timer should be added to ensure personnel meet the required count time.
The background for the change room frisker was elevated due to direct radiation from contaminated lab coats stored nearby. The elevated background required that the frisker be operated on the X10 (0-5000 cpm) scale rather than the X1 scale. Frisker relocation or additional shielding is needed to improve the detection capability of thi in-strument.
Based on the appraisal findings, the following improvements are needed to achieve an acceptable personal contamination detection program:
(1) posting of proper use instructions at monitoring locations, (2) better use of contamination detection equipment to match equipment characteristics to the contamination hazard, (3)
improved adherence to procedures for equipment use and source checks, and (4) revision of procedures to better define equipment selection, use, and testing to ensure optimal contamination detection capability. The following improvements are aI:.o desirable:
(1)
provide additional worker training in use and detection capabilities of contamination detection equipment, (2) increase the counting time of the guardhouse portal morator, (3) install an alarning timer on the guardhouse portal monitor, and (4) lower the background of the change room frisker by shielding or relocation.
l c.
Continuous Air Monitors
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Five continuous air monitors (CAM's) monitor airborne radioactivity within the plant. These monitors include both fixed and moving particulate filter units.
(Iodine determination is provided by grab sampling.) These monitors provide acceptable general trend indica-i tion. Calibration includes pulse generator and source response checks but does not include air flow meter calibration. Licensee personnel I.
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indicated that flow meter calibration would be included in future cal-ibrations. The licensee's constant air monitor instrumentation program will be acceptable with inclusion of air flow meter calibrations.
d.
Area Monitors There are 15 area monitors located throughout the plant. These units consist of halogen quenched GM detectors with both local and control room alarm and readout capability. The control room annunciator panel has reflash capability. Two units have a maximum range of 100 R/hr while the remaining 13 have a maximum range of 10 R/hr. The latter units may be of limited value in accidents involving large fission product releases. The licensee intends to install two high range containmen* accident monitors. An existing monitor, ouside con-tainment, can be used to estimate containment radiation levels.
Instructions will be needed to account for shielding present.
Area monitors are calibrated during rsfueling outages (12-18 month intervals) and are tested biweekly for response to an internal check source. Procedures covering calibration and biweekly checks appearei adequate except that the calibration procedure HSP 2.7 does not in-clude acceptance criteria. An intercomparison of control room and local area monitor readout with a calibrated NRC dose rate instrument indicated reasonable agreement.
Based on the appraisal findings, definition of calibration acceptance criteria is needed to achieve a fully acceptable program in this area.
e.
Effluent Monitors Liquid and airborne (gaseous and particulate) effluent monitors provide indication and perform control functions for radioactive releases. Only gaseous releases are routinely quantified from monitors.
The etaluent monitors were last calibrated during the previous
? fueling outage (first half of 1979). The following potential problems were noted in review of these calibrations.
(1) Liquid monitors were calibrated with three liquid mixtures of varying concentration but the isotopic ratios were not similar in the three mixtures. The isotopic variation affects the calibration due to energy response characteristics of the detector. Although the NaI scintillation detectors used with the liquid monitors are not as sensitive to energy variations as some detectors, such error could have easily been eliminated by a more judicious choice of calibration mixtures.
(2) Gaseous monitor calibrations were per-formed at only one point and extrapolated assuming a linear response with a unity slope or at multiple points using mixtures of signifi-cantly different isotopic compositions. Neither method is rigorously
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correct. The calibration should be performed with mixtures of similar isotopic composition or monitor linearity should be verified during the calibration. The latter technique easily allows generation of a family of calibration curves, one for each istopic composition used.
A. high range noble gas monitor, which monitors the existing stack sample line through several inches of lead, was installed to provide interim high range monitoring per NUREG-0578. The following problems were noted with this monitor.
(1) The highest usable range of the monitor is about IE2 Ci/sec according to the licensee's calibration data.
NUREG-0578 specifies an upper range of IE4 Ci/sec. The li-censee had earlier notified NRC (NRR) that the upper range was greater than IE6 Ci/sec.
(2) Operating procedures for the monitor do not addrest background correction. Expected accident radiation fields at the monitor location had not been calculated.
(3) Release calculations do not include energy corrections.
Significant energy variation is expected over the duration of an accident. This energy variation can introduce large quantification errors if not accounted for.
The high range noble gas monitoring problems noted above were discussed at the exit interview. Although the licensee agreed to notify NRR regarding these problems ir. mediately (October 3, 1980), NRR was not contacted by telephone until October 7, 1980, with written notification mailed on October 13, 1980 (dated October 10, 1980). There did not appear to be a compelling reason for the delay in notifying NRR.
Based on the appraisal findings, the noted high range noble gas monitoring problems require resolution to a.:hieve a fully acceptable program. Additionally, improvements in liquid and gaseous calibration methods shoul.i be considered.
10.
ALARA Although actions which promote ALARA principles were noted on both the working and management levels, a formalized comprehensive ALARA program is lacking. The Appraisal Team believes that a well defined and documented
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ALARA effort is needed to ensure consistent ALARA application among
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various workers and work groups and over relatively long time periods.
Radiation doses have averaged slightly less than 200 man-rems per year l
for several years. While this number is significantly less than the l
average for boiling water reactors, the licensee's rated capacity and l
generated power are also significantly less than average. This is re-l flected in the licensee's average man-rems per megawatt year figure, which is significantly greater than average. The Appraisal Team be-
lieves that, while the licensee's personal exposures are not excessive, l
improvement is desirable.
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Dedication to dose reduction on the part of the entire plant staff is needed to effect a truly meaningful ALARA effort. Plant management appeared interested and active in personal dose reduction, as evidenced by the routine reviews of significant jobs in Operations Review Committee meetings. However, the licensee does not have a formal system requiring such review and for spccifying criteria for selection, review, and document-ation.
Other ALARA implementation tools, not presently formalized by the licensee, which should be included in the ALARA program are:
(1) establishment of dose or dose reduction goals for specific jobs and time periods, (2) pro-mulgation of a manage 1ent policy statement supporting ALARA, (3) assign-ment of responsibilities for ALARA activities, (4) establishment of criteria and guidance for ALARA reviews of procedures, work permits, and design changes, and (5) documentation of ALARA reviews.
Additionally, the establishment of systems for documenting and correcting radiation associated problems and for encouraging feeaback from health physics technicians and other plant workers would be beneficial.
The licensee's present ALARA efforts, although fairly good, are conducted with little formal structure. They are highly dependent upon incumbent management personnel for implementation. The Appraisal Team believes that a more formal system, incorporating the items noted above, is necessary to improve and ensure continuity in the ALARA program.
Based on the appraisal findings, implementation of a more formalized ALARA program, including adequate means for ensuring the effectiveness of the program at all plant levels, is required to achieve a fully acceptable program in this area.
11.
Radioactive Waste Radioactive effluents have been generally acceptable over the past several years.
Improvements, noted below, should be considered to upgrade the licensee's performance in this area.
a.
Airborne Effluent Control Airborne radioactivity releases have been relatively low since modification of the offgas system in 1977. A nominal factor of 17 decrease for noble gases was achieved by use of a recombiner and a change in the release flowpath to achieve additional delay time before release. Additional charcoal adsorbers and particulate filters reduced iodine and particulate releases also. Airborne releases are significantly below the BWR average for activity released and are about average when normalized for electrical power generated.
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o Noble gas releases are quantified from offgas monitors; iodine and particulate releases are quantified from continuous stack samples.
Use of the offgas monitors (including the vault monitor) does not account for noble gas releases from ventilation, gland seal exhaust, or mechanical vacuum pump sources. The licensee had estimated these releases at less than one percent of the offgas system releases several years ago.
Although this ratio probably has increased significantly since modification of the offgas treatment system current data were not available. The licensee should review this matter and ensure that all significant noble gas releases can be quantified. Efforts to date to use the installed stack noble gas monitor *o quantify routine releases have been inconclusise, due to backgrou.d radiation variability at the monitor location. The monitor c.a, however, be used to quantify relatively high release rates.
Conversion information needed to derive release information from the monitor readout was not in the control room or immediately available to control room personnel when checked during the appraisal.
The information was available to the shift health physics technicians.
A special high range noble gas monitor is installed for temporary use for quantification of releases beyond the range of the eriginal monitor.
(See Section 9.e for further information.)
The representativeness of the stack particulate sampler had been questioned by the NRC during inspections in the past.
In response to these concerns, the licensee revised the sampling arrangement and completed installation of an isokinetic flow splitter during 1979. The flow splitter specifications were not available for review during the appraisal but will be reviewed at a later time.
The sample flow rates had changed (100% increase) shortly before the Appraisal Team's arrival onsite due to failure ara replacement of the original sample pump.
The deleterious effect of the flow rata change on the isokinetic properties of the sampler had not been recognized by licensee personnel, although the flow rate was routinely recorded by a health physics technician. The sample flow rate was returned to the established value during the appraisal. The sample system was inoperable for several hours at the time of the pump failure.
The significance of operability of the sample pump apparently
!
was not recognized by the shift health physics technician and consequently the pump was not replaced as expeditiously as de-sirable.
The Appraisal Team believes that the health physics technicians should be sufficiently familiar with equipment under their purview to recognize obvious problems such as im-proper sample flows and the significance of inoperable equipment.
An additional problem related to stack sampling was the lack of a procedure for analyzing high activity iodine cartridges (possible under certain accident conditions). Estimates of expected radio-
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activity levels on the cartridges had not been made; therefore, predetermined criteria for proper selection of analytical equipment were not available. Ncr had extended distance calibrations been conducted to accommodate high activity cartridges on the licensee's analytical equipment. As noted in Section 13, a procedure for emergency iodine quantification appeared erroneous.
An unplanned airborne release occurred during July 1980. The release, below regulatory limits, was significant in that diffi-culties encountered in the quantification exemplified continued weakness in the technical ability of the licensee's staff. The Radiation Protection Engineer had only recently arrived onsite at the time of the release.
In addition to the quantification problem, the release was unmonitored.
It appears probable that small unmonitored airborne releases occur routinely through the oil storage room exhaust, since a portion of the air supply to the room is from the turbine building. This matter is being reviewed by the licensee.
Based on the appraisal findings, improvements in accident iodine analysis procedures and stack gaseous monitor conversion informa-tion availability are needed to achieve a fully acceptable pro-gram in this area. Additionally, unquantified noble gas release paths should be evaluated for their contribution to total plant noble gas releases.
b.
Liquid Effluent Control Although the liquid releases from the site have been within regulatory limits, the annual quantities have been above the BWR averages (significantly above when normalized for electrical power generated).
These releases are attributable to a lack of cleanup treatment. The radwaste evaporator has been inoperable for several years and an installed demineralizer normally is not used; waste liquid is not reused within the plant. Therefore, most radioactive liquid waste is released without treatment. Reduction of the radioactivity released in liquid discharged from tha plant is desirable and appears readily achievable through increased use of installed treatment equip-ment.
In an attempt to minimize liquid waste generation, the licensee normally does not regenerate resins. Additionally, the installation of a dry cleaning machine during 1980 has reduced radioactive liquid wastes somewhat.
Radioactive liquid releases are made on a batch basis and quantified based upon prerelease and post-release analyses.
Liquid release permits are used to provide management control over the releases, including determination of allowable release rate and liquid effluent monitor alarm setpoint.
Selected release records
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were reviewed. No significant discrepancies were identified.
The licensee's actions in response to IE Bulletin 80-10 (non-radioactive system contamination) were reviewed. No significant g
problems were identified with the licensee's reply. No nonradio-active systems were contaminated. As a result of the licensee's
'
review, additional sampling has been instituted for the heating boiler.
Based on the appraisal findings, this portion of the licensee's i
program appears generally acceptable.
Improved cleanup treatment of liquid radioactive wastes, however, should be implemented.
c.
Solid Radioactive Waste The major sources of solid waste are demineralizer resins (primary purification, fuel element storage well, radwaste, and condensate),
and general plant wastes (filters, paper, plastic, wood, piping, etc.).
In the first nine months of 1980, four cubic meters of resins and 40 cubic meters of general plant wastes were shipped to burial grounds in Nevada and South Carolina. Historically, the licensee's solid radioactive waste volume has been relatively low. This is attributable to segregation of contaminated and noncontaminated wastes, axtensive use of a compactor for most general plant wastes, and use of dewatering rather than solidification for spent resins.
As a result of fuel element integrity problems, primary purification resins generated from 1977 to 1979 contained transuranic materials exceeding ten nanocuries per gram of waste.
Contaminated wastes con-taining greater than ten nanocuries of transuranic materials per gram of waste no longer can be shipped to commercial disposal facilities.
The licensee believes that the reactor coolant system has been cleaned sufficiently that future primary purification demineralizer resins will be below the disposal limit.
If not, the licensee intends to dilute or store the resins. The licensee currently intends to contract for the solidification of resins in 1981 to meet burial site requirements
for solidification of high concentration waste.
If necessary, the licensee has plans for building a storage facility, on the east side cf the waste treatment building, capable of storing eleven resin liners (about five years capacity).
f
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The licensee's practice of storing waste filled 55 gallon drums outdoors poses potential problems. Four such drums containing compacted trash care opened during this appraisal. One drum was found to contain some liquid (withis present burial site limita-tions), possibly the result of a seam separation in the lid gasket.
Due to the increased restrictions on liquid in radwaste shipments due in 1981, inside storage of packaged radwaste appears desirable.
One additional problem noted was that the locking nut on more than
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25 percent of the 55-gallon drums being held for shipment had not been secured as required by plant procedure HPS 4.3, Section 6.16.
A cursory survey of the sanitary landfill used by the licensee was performed during this appraisal. No radioactivity was detected.
Noncontaminated combustible waste from within the radiologically controlled plant areas are normally incinerated onsite. This practice appeared acceptable.
Periodic radiation checks are made of the incinerator residue.
Concrete lined 55 gallon drums are used to package highly radio-active filters for disposal. Although procedures exist for filter changeout up through placement of the spent filter in the drum (HSP 4.5), procedures for the remainder of the packaging operation were not available. Licensee personnel stated that a semi-dry mixture of cement is added to the drum. Although no specific problems with this practice were noted, the high radiation levels and stringent disposal requirements involved appear to dictate a need for more complete procedures.
Based on the appraisal findings, this portion of the licensee's program appears generally acceptable. However, the following matters should be considered for improvement of the program:
(1) provide protection from the weather for waste-filled drums, (2) ensure adherence to procedure HSP 4.3 (locking nuts), and (3) provide detailed procedures for packaging highly radioactive filters.
12.
Facilities The facilities available to the Health and Safety Department appear marginally adequate for normal operations and initial accident condi-tions. Desirable improvements are noted below. These improvements involve expansion and relocation of work space for radiation protection personnel and increased use of the primary access control point (change room) as a focal point for radiation protection information.
a.
Chemistry and Counting Laboratory The plant chemistry and analytical facilities, located in the turbine building, contain only marginally adequate workspace.
Radiation pratection activities are also conducted out of this limited workspace. Laboratory ventilation is supplied from the old administration building ventilation system with exhaust to the turbine building or to atmosphere through a filtered hood.
An environmental laboratory located in the new administration building (outside of the guardhouse) is the designated backup laboratory for post-accident analytical work.
Current plans call for movement of analytical instrumentation to the north assembly point, the Genoa 1 building, if both laboratories are unusable.
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The licensee has two GeLi multichannel analyzers utilizing a Nuclear Data 6600 computer,.three internal proportional counters, and a liquid scintillation-counter. Quality assurance for the laboratory's analytical measurements appeared adequate, no significant discrepancies from Regulatory. Guide 4.15 recommen-
,
dations were identified. Radiological samples, split routinely with the NRC, have yielded generally satisfactory.results. The multichannel analyzer is calibrated annually; source checks are run daily.
Internal proportional counter efficiency control charts are updated daily.
This portion of the licensee's program appears generally acceptable.
b.
Radiation Protection Facilities The primary access control point into the radiologically restricted area contains space to hang used lab coats, restroom facilities, a washer / dryer for " clean" laundry, a first aid cabinet, decon-
- t tamination showers, a supply of clean protective clothing, a per-sonnel status board, a portal monitor, and a frisker. As noted in Sections 8 and 9, the sensitivity of the frisker was adversely affected by fixed contamination on the lab coats hanging nearby.
The health physics technicians work out of the chemistry / counting laboratory. The access control point is atypical from that found in most plants in that health physics technicians are not stationed
,
at or near the area, and current radiation / contamination survey data and copies of special work permits, etc., are not maintained'in
access control for review by workers. The licensee does not. appear to be utilizing the access control point as effectively as desirable
for providing radiation protection information and assistance.
In addition to providing radiation protection assistance, the presence of a health physics technician at the access control point may en-
,
courage stricter adherence to radiation protection practices.
(See l
Sections 8 and 9.)
i In addition to the health physics technician work space being
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remote from the access control point, the health physics super-visory offices, located in a newly constructed administration
building outside of the guardhouse, are remote from both the l
health physics technician workspace and the access control point.
Such location discourages close contact with the health physics
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Based on the appraisal findings, this portion of the licensee's program appears marginally acceptable; the following items should be considered for improvement:
(1) relocation of the health physics technicians to the' access control point, (2) increased i
health physics technician work space, (3) relocation of health physics supervisory personnel closer to the health physics tech-nicians and plant activities, and (4) provision of better radiation
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protection information at the access control point.
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o 13.
Accident,Re-entry The scope of the appraisal in this area was limited to the Health and Safety Department's accident and re-entry preparedness capability.
The appraisal primarily focused on:
instrumentation, analytical laboratory, re-entry, expanded support, training, and environmental monitoring. While efforts in these areas have been undertaken as a result of TMI, additional improvement in certain areas, especially in re-entry preparedness and training, appear warranted.
Survey and sampling equipment are available for in tial response to an accident. The survey instrument supply appears adqeuate. The four ciergency kits appeared to be adequately stocked, except that personal m>nitoring devices (TLD's) should be included in each kit.
The licensee is continuing to upgrade area and effluent monitoring capa-bilities.
Au emergency plan has been implemented.
Refinements to the existing emergency preparedness documentation is continuing. On the basis of discussions with the Health and Safety Department staff, it appears that additional intradepartmental training, especially in sample collection and analysis, would better prepare the Department to respond to a radiological emergency.
Short-term post-accident reactor coolant and plant atmosphere sampling and analysis methods are described in procedure EPP-21, " Sample Collection and Analysis During Emergencies." Reactor coolant sampling aspects of EPP-21 appeared adequate. Selected personnel have been trained in the sampling / analysis procedure but hands-on training has not been conducted.
Simulated sample collection, transport, and analysis should be conducted to identify potential problems with remote handling equipment, shielded containers, or other special equipment.
In addition, training should be expanded to include all technicians who may be involved in the sampling /
analysis operations.
The plant atmosphere sampling aspects of EPP-21 are generally acceptable except for procedures describing use of a single channel analyzer in lieu of multichannel analyzers for iodine quantifi-cation. Licensee personnel were not able to justify the counting technique described in the procedure nor had the procedure's credibility been demonstrated through use.
The licensee had not intended to use silver zeolite for iodine collection, no silver zeolite cartridges were onsite.
The licensee's emergency procedures only minimally address recovery and re-entry details. A certified health physicist (ABHP) is on the corporate staff and could provide assistance to the health physics personnel in an accident situation. Emergency environmental monitor-ing is described in procedure EPP-8 " Initial Offsite Radiological Su rvey. " Responsible personnel were knowledgeable of their duties
per EPP-8.
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A separate NRC evaluative effort is being conducted regarding reactor emergency planning activities. The emergency planning evaluation for LACBWR has been initiated but is not yet complete.
In light of this ongoing effort the Appraisal Team has refrained from evaluating the licensee's overall emergency response capability. Additional training, however, appears needed for health physics technician emergency activities, including sampling and analysis techniques, as noted above.
14.
Exit Interview The Appraisal Team met with licensee representatives (denoted in Section 1) at the conclusion of the appraisal on October 3, 1980. The Appraisal Team summarized the scope and findings of the appraisal. The findings E
are grouped intc three categories:
a.
Significant appraisal findings are contained in Appendix A to the letter forwarding this report. The licensee's response to these findings, to be submitted in writing, will be reviewed upon receipt.
b.
Findings.of lesser significance, but which are considered instrumental
,'
to improvement of the licensee's health physics program, are summarized at the conclusion of the applicable sections or subsections of this report. The licensee's actions in response to these items will be reviewed during subsequent inspections.
c.
Three noncompliance items are specified in Appendix B to the letter forwarding this report. The licensee's response to these findings, to be submitted in writing, will be reviewed upon receipt.
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